IRS Issues PLR Waiving QDOT Conveyance Requirement for Post-Citizenship Marital Deduction

The IRS has issued a private letter ruling on I.R.C. §§2056 and 2056A and Treas. Regs. §§301.9100 and 20.2056A granting a waiver of the actual conveyance requirement for assets irrevocably assigned to a qualified domestic trust (QDOT) where the surviving spouse became a United States citizen after the decedent’s death but before completing the property transfer, allowing the estate to claim the marital deduction despite the incomplete conveyance. [PLR 202623004]

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