• The purpose of the marital deduction is to permit deferral of estate taxes until the death of the surviving spouse. But this property is included in the surviving spouse’s estate at death, where it is subject to the federal estate tax. — Abbr. QTIP. See QTIP trust under TRUST. [Cases: Internal Revenue 4169(4). C.J.S. Internal Revenue §§ 536–537.]
qualified terminable interest property
Property that passes by a QTIP trust from a deceased spouse to the surviving spouse and that (if the executor so elects) qualifies for the marital deduction provided that the spouse is entitled to receive all income in payments made at least annually for life and that no one has the power to appoint the property to anyone other than the surviving spouse.
