# Treas. Reg. § 20.2056A-12: Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.

Source: eCFR as of 2026-10-19 <https://www.ecfr.gov/current/title-26/section-20.2056A-12>. Interprets 26 U.S.C. § 2056A.

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. 

[T.D. 8612, 60 FR 43551, Aug. 22, 1995]