Description
An adviser’s guide to the citizenship test that governs the marital deduction and the three transfer tax positions domicile assigns, lifetime gifts and the $194,000 annual exclusion for a non-citizen spouse, jointly held property and the marital property regimes, the qualified domestic trust required to preserve the deduction at the first death, retirement accounts, annuities and life insurance, the treaty marital relief available under the German, French and Canadian conventions and the domicile protection of the other conventions, portability, the credit for tax paid, naturalization and expatriation, the state estate taxes, the calendar of the first death, and the steps a couple takes while both spouses are alive. 30 pages. Updated in September 2026.