26 CFR § 20.2056A-12 - Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.

---
identifier: "/us/cfr/t26/s20.2056A-12"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 20.2056A-12 - Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT."
title_number: 26
title_name: "Internal Revenue"
section_number: "20.2056A-12"
section_name: "Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "B"
subchapter_name: "ESTATE AND GIFT TAXES"
part_number: "20"
part_name: "ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805."
regulatory_source: "T.D. 6296, 23 FR 4529, June 24, 1958; 25 FR 14021, Dec. 31, 1960, unless otherwise noted."
cfr_part: "20"
---


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

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]