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In a QTIP trust, can the grantor-spouse allocate the GST exemption to the trust property?

Yes, the exemption can be allocated.

The main idea is that the generation-skipping transfer (GST) exemption can be allocated to a trust, including a QTIP trust, by the grantor-spouse. When a QTIP trust is funded, the grantor can designate that part of their GST exemption applies to the trust property. This makes future transfers from the trust to skip persons (for example, grandchildren) shielded from GST tax up to the amount allocated. The allocation is done through the applicable GST tax election on the relevant tax return (gift or estate, as appropriate). It is not required to allocate the exemption to all property, and the trustee’s consent is not a prerequisite for the grantor’s GST exemption allocation.

No, it cannot be allocated.

It must be allocated to all property.

It cannot be allocated without consent of trustee.

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