Temporary Regs Provide Guidance on EGT Portability Election
(Parker's Federal Tax Bulletin: June 22, 2012)

SUMMARY: The IRS has issued temporary regulations which provide additional guidance on the recently enacted rules allowing the portability of the applicable estate and gift tax exclusion amount between spouses. T.D. 9593 (6/18/12).

In December 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (TRUIRJCA) amended Code Sec. 2010(c) to allow portability of the applicable estate and gift tax exclusion amount between spouses. Code Sec. 2010(c)(2) defines the applicable exclusion amount, used to determine the applicable credit amount, as the sum of the basic exclusion amount and, in the case of a surviving spouse, the deceased spousal unused exclusion (DSUE) amount. The basic exclusion amount is $5 million, which is adjusted for inflation in each year after calendar year 2011. For 2012, the basic exclusion amount is $5,120,000. (As currently written, the portability provision applies only with respect to deaths occurring in 2011 and 2012. After 2012, the portability provision is scheduled to sunset, and the estate and gift taxes are scheduled to return to their pre-2001 levels, which included an applicable exclusion amount of $1 million.)

Special rules apply to the portability of a DSUE amount. For example, there are certain requirements that must be met to allow a surviving spouse to take into account a DSUE amount. In particular, the executor of the estate of the deceased spouse must file an estate tax return, compute the DSUE amount on that return, elect portability of the DSUE amount on that return, and ensure that the return is filed by the due date (including extensions) for filing the return. The IRS can examine a return of the deceased spouse to determine the DSUE amount, even after the statute of limitations has expired.

As a result of the new portability provisions, practitioners had many questions about applying the provisions. The IRS has now issued temporary regulations in T.D. 9593 (6/18/12) that clarify how the rules should be applied and answer many of those practitioner questions.

Sections of the temporary regulation relating to portability of a deceased spousal unused exclusion amount apply to estates of decedents dying on or after January 1, 2011. Other provisions apply to estates of decedents dying on or after June 15, 2012. The temporary regulations relating to the unified credit against the gift tax apply to gifts made on or after January 1, 2011, while the other gift tax provisions apply to gifts made on or after June 15, 2012.

Applicable Terminology

For purposes of understanding and applying the temporary regulations, it is important to understand the following terms:

(1) Applicable credit amount This is the allowable credit against estate tax and gift tax. The applicable credit amount equals the amount of the tentative tax that would be determined if the amount on which the tentative tax is to be computed were equal to the applicable exclusion amount. The applicable credit amount is determined by applying the unified rate schedule in Code Sec. 2001(c) to the applicable exclusion amount.

(2) Applicable exclusion amount This is the sum of the basic exclusion amount and, in the case of a surviving spouse, the DSUE amount.

(3) Basic exclusion amount This is the sum of (1) for any decedent dying in calendar year 2011, $5 million; and (2) for any decedent dying after calendar year 2011, $5 million multiplied by the cost-of-living adjustment.

(4) Deceased spousal unused exclusion (DSUE) amount This amount refers, generally, to the unused portion of a decedent's applicable exclusion amount to the extent this amount does not exceed the basic exclusion amount in effect in the year of the decedent's death.

(5) Last deceased spouse The term last deceased spouse means the most recently deceased individual who, at that individual's death after December 31, 2010, was married to the surviving spouse.

Background

In Notice 2011-82, the IRS alerted taxpayers to the requirements for the estate of a deceased spouse to elect portability of a DSUE amount. In addition, Notice 2011-82 announced that the estate of a deceased spouse is deemed to elect portability of the DSUE amount by timely filing a complete and properly-prepared estate tax return, and that this return will be deemed to include a computation of the DSUE amount until such time as the IRS revises the estate tax return to expressly contain the DSUE amount computation. The notice also provided guidance to the estates of deceased spouses who choose not to make the portability election.

Subsequently, in Notice 2012-21, the IRS granted to qualifying estates a six-month extension of time for filing an estate tax return to elect portability of an unused exclusion amount provided that the qualifying estate files Form 4768, Application for Extension of Time to File a Return and/or Pay U.S. Estate (and Generation-Skipping Transfer) Taxes, within 15 months of the decedent's death. A qualifying estate is the estate of a person who died, survived by a spouse, during the first half of calendar year 2011, and whose gross estate has a fair market value that does not exceed $5 million. With the extension granted by Notice 2012-21, the estate tax return must be filed within 15 months of the decedent's death.

Making the Portability Election

The temporary regulations require an executor electing portability to make that election on a timely-filed estate tax return. The last return filed by the due date of the return, including extensions actually granted, will supersede any previously-filed return. Thus, an executor may supersede a previously-filed portability election on a subsequent timely-filed estate tax return.

An executor or administrator of the estate of a decedent (survived by a spouse) that is appointed, qualified, and acting within the United States (an appointed executor), may file the estate tax return on behalf of the estate of the decedent and, in so doing, elect portability of the decedent's DSUE amount. An appointed executor also may elect not to have portability apply. If there is no appointed executor, any person in actual or constructive possession of any property of the decedent (a non-appointed executor) may file the estate tax return on behalf of the estate of the decedent and, in so doing, elect portability of the decedent's DSUE amount, or, by complying with certain requirements, may elect not to have portability apply. A portability election made by a non-appointed executor cannot be superseded by a contrary election made by another non-appointed executor of that same decedent's estate (unless such other non-appointed executor is the successor of the non-appointed executor who made the election).

The temporary regulations provide that a portability election is irrevocable once the due date (as extended) of the return has passed.

Under Code Sec. 6075(a), an estate tax return must be filed within nine months of the date of the decedent's death. An estate tax return must be filed when the gross estate of a citizen or resident exceeds the excess (if any) of the basic exclusion amount in effect in the calendar year of the decedent's death over the sum of the decedent's adjusted taxable gifts and the amount allowed to the decedent as a specific exemption under Code Sec. 2521 as in effect before its repeal by the Tax Reform Act of 1976.

When an executor is not required to file an estate tax return, the Code does not specify a due date for a return filed for the purpose of making the portability election. The temporary regulations require every estate electing portability of a decedent's DSUE amount to file an estate tax return within nine months of the decedent's date of death, unless an extension of time for filing has been granted.

Requirement to File a Complete and Properly-Prepared Estate Tax Return

As noted above, in Notice 2011-82, the IRS provided that the estate of a decedent dying after December 31, 2010, will be deemed to make the portability election upon the timely filing of a complete and properly-prepared estate tax return. The temporary regulations provide that the estate of a decedent (survived by a spouse) makes the portability election by timely filing a complete and properly-prepared estate tax return for the decedent's estate.

Tax practitioners questioned what the IRS meant by a complete and properly-prepared estate tax return. Those practitioners requested that the IRS consider the cost and burden associated with filing an estate tax return and establishing and substantiating the values reported on the return for those estates that are not required to file a return but are filing such a return solely to elect portability of the decedent's DSUE amount.

In response, the temporary regulations provide that an estate tax return prepared in accordance with all applicable requirements is considered a complete and properly-prepared estate tax return. However, the temporary regulations also provide that executors of estates that are not otherwise required to file an estate tax return do not have to report the value of certain property that qualifies for the marital or charitable deduction. If an executor chooses to use this special rule in filing an estate tax return, the executor must estimate the total value of the gross estate (including the values of the property that do not have to be reported on the estate tax return under this provision), based on a determination made in good faith and with due diligence regarding the value of all the assets includible in the gross estate.

PRACTICE TIP: According to the IRS, the estate tax return instructions will provide ranges of dollar values, and the executor must identify on the estate tax return the particular range within which falls the executor's best estimate of the total gross estate. An amount corresponding to this range will be included on Line 1, Part 2, of the estate tax return, along with an indication of whether the Line 1 total includes an estimate under this special rule. By signing the return, the executor is certifying, under penalties of perjury, that the estimate falls within the identified range of values to the best of the executor's knowledge and belief. The inquiry required to determine the executor's best estimate is the same an executor of any estate must make under current law to determine whether the estate has a filing obligation; that is, to determine whether the fair market value of the gross estate exceeds the excess of the basic exclusion amount over the sum of the decedent's adjusted taxable gifts and the amount allowed to the decedent as a specific exemption under Code Sec. 2521.

Opting Out of Portability Election

If the executor of the estate of a decedent with a surviving spouse does not wish to make the portability election, the temporary regulations require the executor to make an affirmative statement on the estate tax return signifying the decision to have the portability election not apply. If no estate tax return is required for that decedent's estate, not filing a timely return will be considered to be an affirmative statement signifying the decision not to make a portability election.

Executor Responsible for Making Portability Election

A practitioner suggested that the temporary regulations allow a surviving spouse to file an estate tax return on behalf of a decedent independently of a duly-appointed executor if the surviving spouse notifies the executor of the intention to file and the executor does not, in fact, file a return. The IRS responded that Code Sec. 2010(c)(5), allows only the executor of the decedent's estate to file the estate tax return and make the portability election. Code Sec. 2203 defines the term executor for purposes of the estate tax to mean the executor or administrator of the decedent, or, if there is no executor or administrator appointed, qualified, and acting within the United States, then any person in actual or constructive possession of any property of the decedent.

The temporary regulations provide that an executor or administrator that is appointed, qualified, and acting within the United States for the decedent's estate (an appointed executor), may file an estate tax return to elect portability or to opt to have the portability election not apply. The temporary regulations provide that, if there is no appointed executor, any person in actual or constructive possession of any property of the decedent may file the estate tax return to elect portability or to opt to have the portability election not apply. The temporary regulations refer to such a person as a non-appointed executor and provide that a portability election made by a non-appointed executor cannot be superseded by a contrary election made by another non-appointed executor of that same decedent's estate.

Computing the DSUE Amount

Computation Required On Estate Tax Return to Elect Portability

The temporary regulations require that an executor include a computation of the DSUE amount on the estate tax return of the decedent to allow portability of that decedent's DSUE amount. A complete and properly-prepared return contains the information required to compute a decedent's DSUE amount. Accordingly, in a transitional rule consistent with Notice 2011-82, the temporary regulations provide that the IRS will deem the required computation of the decedent's DSUE amount to have been made on an estate tax return that is considered complete and properly-prepared. The temporary regulations further clarify that, once the IRS revises the prescribed form for the estate tax return expressly to include the computation of the DSUE amount, executors that previously filed an estate tax return under the transitional rule will not be required to file a supplemental estate tax return using the revised form.

Method of Computing the DSUE Amount

Code Sec. 2010(c)(4)(A) and Code Sec. 2010(c)(4)(B)(i) and (ii) define the DSUE amount as the lesser of (1) the basic exclusion amount, or (2) the excess ofbasic exclusion amount of the last deceased spouse of the surviving spouse, over the amount with respect to which the tentative tax is determined on the estate of such deceased spouse.

The temporary regulations confirm that the term basic exclusion amount means the basic exclusion amount in effect in the year of the death of the decedent whose DSUE amount is being computed. Generally, only the basic exclusion amount of the decedent, as in effect in the year of the decedent's death, will be known at the time the DSUE amount must be computed and reported on the decedent's estate tax return. Because Code Sec. 2010(c)(5)(A) requires the executor of an estate electing portability to compute and report the DSUE amount on a timely filed estate tax return, and because the basic exclusion amount is integral to this computation, the term basic exclusion amount in Code Sec. 2010(c)(4)(A) necessarily refers to such decedent's basic exclusion amount.

In responding to Notice 2011-82, several practitioners argued that the reference to basic exclusion amount in Code Sec. 2010(c)(4)(B)(i) should be interpreted to mean applicable exclusion amount, citing to the computation of the DSUE amount in Example 3 on page 53 of the Technical Explanation and to footnote 1582A that was added to the General Explanation by the ERRATA General Explanation of Tax Legislation Enacted in the 111th Congress (ERRATA).

According to the IRS, Example 3 computes the DSUE amount of a deceased spouse who was preceded in death by one spouse and was survived by another spouse. The deceased spouse's DSUE amount is computed using the applicable exclusion amount rather than the basic exclusion amount of the deceased spouse (as reduced by the amount of the deceased spouse's taxable estate). Example 3 is reproduced verbatim in the General Explanation. See JCS-2-11 at page 555. The ERRATA acknowledges that Code Sec. 2010(c)(4)(B)(i) uses the term basic exclusion amount, but notes that [a] technical correction may be necessary to replace the reference to the basic exclusion amount of the last deceased spouse of the surviving spouse with a reference to the applicable exclusion amount of such last deceased spouse, so that the statute reflects intent.

According to the IRS, construing the language of Code Sec. 2010(c)(4)(B)(i) as referring to the same number described in Code Sec. 2010(c)(4)(A) would lead to an illogical result because it would effectively render the use of basic exclusion amount in Code Sec. 2010(c)(4)(A) meaningless. Specifically, the basic exclusion amount (the amount referenced in Code Sec. 2010(c)(4)(A)) cannot be less than that same number reduced by another number (the amount referenced in Code Sec. 2010(c)(4)(B)). Under such an interpretation, the basic exclusion amount referenced in Code Sec.could not limit or impact the DSUE amount, and thus it would serve no purpose as written. Based on the principle that a statute should not be construed in a manner that renders a provision of that statute superfluous and consistent with the indicia of legislative intent reflected in the Technical Explanation and the General Explanation, and in the exercise of the express authority granted by Congress in Code Secs. 2010(c)(6) and 7805, Treasury and the IRS have determined that the reference in Code Sec. 2010(c)(4)(B)(i) to the basic exclusion amount is properly interpreted to mean the applicable exclusion amount. Thus, the temporary regulations adopt this interpretation.

Effect of Gift Taxes Paid and Payable on Computing the DSUE Amount

Several practitioners suggested that, for purposes of computing the DSUE amount under Code Sec. 2010(c)(4), the amount referred to in Code Sec. 2010(c)(4)(B)(ii), which is the amount on which the decedent's tentative tax is determined under Code Sec. 2001(b)(1), be construed to take into account gift tax paid by such decedent. The practitioners noted that, to avoid using exclusion for amounts on which gift tax was paid, this construction should apply in computing the DSUE amount of such a decedent if (1) gift tax was paid by a decedent on transfers that caused the total of his or her taxable transfers to exceed the applicable exclusion amount at the time of the transfer, and (2) the total adjusted taxable gifts of the decedent is less than the applicable exclusion amount on the date of his or her death. The temporary regulations provide that amounts on which gift taxes were paid by a decedent are excluded from adjusted taxable gifts for the purpose of computing that decedent's DSUE amount.

Potential Impact of Credits in Code Sections 2013 - 2015 on the DSUE Amount

Practitioners requested clarification as to whether the DSUE amount is determined before or after applying other available credits, such as the credit for tax on prior transfers (Code Sec. 2013), the credit for foreign death taxes (Code Sec. 2014), and the credit for death taxes on remainders (Code Sec. 2015). According to the IRS, the issue of the impact of the credits in Code Secs. 2013 to 2015 on computing the DSUE amount merits further consideration. Thus, the temporary regulations reserve Reg. Sec. 20.2010-2T(c)(3) to provide future guidance on this issue. The IRS is requesting comments regarding appropriate rules to coordinate these credits with portability of the exclusion.

Use of the DSUE Amount by the Surviving Spouse

Date DSUE Amount May Be Taken into Consideration by Surviving Spouse

Practitioners asked for clarification on when the DSUE amount of a decedent is available to the surviving spouse or to the surviving spouse's estate for use in determining the surviving spouse's applicable exclusion amount. The temporary regulations provide that, if the decedent is the last deceased spouse of the surviving spouse on the date of a transfer by the surviving spouse that is subject to gift or estate tax, the surviving spouse, or the estate of the surviving spouse, of that decedent may take into account that decedent's DSUE amount in determining the applicable exclusion amount of the surviving spouse when computing the surviving spouse's gift or estate tax liability on that transfer. This rule applies only if the decedent's executor elected portability. In addition, the temporary regulations provide that a portability election made by the executor of a decedent's estate is effective as of the date of the decedent's death. Thus, the DSUE amount of a decedent survived by a spouse may be included in determining the applicable exclusion amount of the surviving spouse under Code Sec. 2010(c)(2), subject to any applicable limitations, with respect to all transfers occurring after the death of the decedent, if the executor of the decedent's estate makes a portability election and the election is not superseded by the executor of the decedent's estate before the due date of the return, including extensions.

Last Deceased Spouse Limitation on DSUE Amount Available to Surviving Spouse

Some practitioners suggested that the regulations clarify the scope of the last deceased spouse limitation in Code Sec. 2010(c)(4)(B)(i). The temporary regulations explain that the term last deceased spouse referred to in Code Sec. 2010(c)(4)(B)(i) means the most recently deceased individual who was married to the surviving spouse at that individual's death, except that an individual dying before calendar year 2011 cannot be considered the last deceased spouse of such surviving spouse. The temporary regulations clarify that remarriage alone does not affect who will be considered the last deceased spouse and does not prevent the surviving spouse from including in the surviving spouse's applicable exclusion amount the DSUE amount of the deceased spouse who most recently preceded the surviving spouse in death.

The temporary regulations further clarify that the identity of the last deceased spouse of the surviving spouse for purposes of portability is not affected by whether the estate of the last deceased spouse elects portability of the deceased spouse's DSUE amount or whether the last deceased spouse has any DSUE amount available. According to the IRS, this is consistent with the statutory language, which refers to the last deceased spouse of such surviving spouse without further qualification, as well as with the Technical Explanation, which states that [t]he last deceased spouse limitation applies whether or not the last deceased spouse has any unused exclusion or the last deceased spouse's estate makes a timely election.

For purposes of determining the applicable gift tax credit amount under Code Sec. 2505(a)(1), a practitioner asked the IRS to clarify when the identity of the last deceased spouse is determined. The IRS responded that, although Code Sec. 2505(a)(1) refers to the applicable credit amount in effect under Code Sec. 2010(c) as would apply if the donor died as of the end of the calendar year, this does not mean that the identity of the last deceased spouse is subject to change for purposes of computing the surviving spouse's applicable exclusion amount if the surviving spouse is preceded in death by a subsequent spouse after the gift transfer but before the end of the calendar year. Therefore, the temporary regulations provide that for purposes of determining a surviving spouse's applicable exclusion amount when the surviving spouse makes a taxable gift, the surviving spouse's last deceased spouse is identified as of the date of the taxable gift.

DSUE Amount Available in Case of Multiple Spouses and Previously-Applied DSUE Amount

Some practitioners requested that the regulations clarify the outcome when a surviving spouse is preceded in death by more than one spouse. In particular, practitioners asked how the DSUE amount to be included in the applicable exclusion amount of a surviving spouse is affected when a decedent who is currently considered the last deceased spouse of such surviving spouse either has no DSUE amount or has a smaller amount of DSUE in comparison to a decedent who previously was considered the last deceased spouse of such surviving spouse. The temporary regulations clarify that, in either situation, the surviving spouse may not apply any remaining DSUE amount from a prior deceased spouse.

In addition, the temporary regulations address how to compute the DSUE amount included in the applicable exclusion amount of a surviving spouse who made gifts between the deaths of two decedents, each of whom were at separate times the last deceased spouse of such surviving spouse. First, the temporary regulations create an ordering rule by providing that, when a surviving spouse makes a taxable gift, the DSUE amount of the decedent who is the last deceased spouse of such surviving spouse will be considered to apply against the amount of the surviving spouse's taxable gifts for that calendar year before the surviving spouse's own basic exclusion amount will apply.

Second, the temporary regulations compute the DSUE amount available to such a surviving spouse or to his or her estate, respectively, as including both:

(1) the DSUE amount of the surviving spouse's last deceased spouse, and

(2) any DSUE amount actually applied to taxable gifts under the rule in Reg. Sec. 25.2505-2T(b) to the extent the DSUE amount so applied was from a decedent who no longer is the last deceased spouse for purposes of Code Sec.

Under the temporary regulations, a surviving spouse may use the DSUE amount of a predeceased spouse as long as, for each transfer, such DSUE amount is from the surviving spouse's last deceased spouse at the time of that transfer. Thus, a spouse who has survived multiple spouses may use each last deceased spouse's DSUE amount before the death of that spouse's next spouse, and thereby may apply the DSUE amount of multiple deceased spouses in succession. However, this does not permit the surviving spouse to use the sum of the DSUE amounts of those deceased spouses at one time, and a surviving spouse may not use the remaining DSUE amount of a prior deceased spouse following the death of a subsequent spouse.

Applicability of Portability Rules to Nonresidents Who Are Not Citizens

Several practitioners requested that the regulations clarify the applicability of the rules in Code Sec. 2010(c) to estates of nonresidents who are not citizens. In response, the temporary regulations provide that an executor of the estate of a nonresident decedent who was not a citizen of the United States at the time of death may not make a portability election on behalf of that decedent. The temporary regulations provide that a nonresident surviving spouse who was not a citizen of the United States at the time of such surviving spouse's death may not take into account the DSUE amount of any deceased spouse of such surviving spouse, except to the extent allowed under a treaty obligation of the United States.

Applicability of Portability in Case of Qualified Domestic Trusts

When property of a decedent passes to a QDOT, the decedent's estate is allowed a marital deduction for the value of such property. Ultimately, however, estate tax is imposed on such property as distributions constituting taxable events are made from the QDOT. The estate tax imposed by Code Sec. 2056A on a QDOT is the decedent's estate tax liability, and that tax generally equals the amount of additional estate tax that would have been imposed under Code Sec. 2001 if the amount involved in the taxable event had been included in the decedent's taxable estate and had not been deductible. The estate tax that would have been imposed is computed by determining the net tax under Code Sec. 2001 after the allowance of any credits, including the applicable credit amount determined under Code Sec. 2010(c). Consequently, when a QDOT has been created for the benefit of a decedent's surviving spouse, the executor of the decedent's estate will compute a DSUE amount, on a preliminary basis, that may decrease as distributions constituting taxable events under Code Sec. 2056A are made.

The temporary regulations allow the decedent's estate full availability of the decedent's applicable exclusion amount until such time as the final estate tax liability of the decedent is computed. The temporary regulations provide that the executor of a decedent's estate claiming a marital deduction for property passing to a QDOT must compute the decedent's DSUE amount on a preliminary basis on the decedent's estate tax return for the purpose of electing portability, although such amount subsequently will be reduced by the estate tax imposed by Code Sec. 2056A.

The temporary regulations further provide that the DSUE amount of such a decedent is redetermined upon the final distribution or other taxable event on which estate tax under Code Sec. 2056A is imposed, which is generally upon the death of the surviving spouse or the earlier termination of all QDOTs created for that surviving spouse. The earliest date such a decedent's DSUE amount may be included in determining the applicable exclusion amount available to the surviving spouse or the surviving spouse's estate is the date of the event that triggers the final estate tax liability of the decedent under Code Sec. 2056A. Generally, this means that such a decedent's DSUE amount is available for transfers occurring by reason of the surviving spouse's death, but generally will not be available to the surviving spouse during life. However, the decedent's DSUE amount will be available to apply to the surviving spouse's taxable gifts made in the year of the surviving spouse's death, or, if the event terminating the QDOT occurs before the surviving spouse's death, then in the year of that terminating event and/or any subsequent year during the surviving spouse's life.

Disclaimer: This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer. The information contained herein is general in nature and based on authorities that are subject to change. Parker Tax Publishing guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. Parker Tax Publishing assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein.

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