Code of Federal Regulations Title 26. Internal Revenue § 26.20.2056A–12 Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT

Under section 2056A(b)(13), in the case of any distribution from a QDOT on which an estate tax is imposed under section 2056A(b)(1)(A), the distribution is treated as a transfer by gift for purposes of section 1015, and any estate tax paid under section 2056A(b)(1)(A) is treated as a gift tax. See § 1.1015–5(c)(4) and (5) of this chapter for rules for determining the amount by which the basis of the distributed property is increased.