Final regulations under Code Sec. 2056A have been adopted, applicable specifically to the estates of decedents that are passing property in a qualified domestic trust (QDOT) to (or for the benefit of) a noncitizen spouse.
The final regulations update the titles of the IRS officials authorized to enter into agreements related to Code Sec. 2056A and grant extensions of time to file or pay estate tax owing under Code Sec. 2056A, correct outdated references, procedures, and the addresses to which trustees should provide security instruments required for qualifying as a QDOT, and update the definition of “finally determined” to eliminate an outdated reference to the issuance of an estate tax closing letter. The final regulations apply on and after July 10, 2026.
