Federal Estate Tax Deduction for Connecticut Estate Tax Must Be Reduced to Account for Tax Imposed on Add-Back of Connecticut Gift Taxes Paid Within Three Years of Death

The IRS addressed a special issue impacting the estate tax deduction under IRC §2058 for amounts paid for state estate, inheritance, legacy or succession taxes under Connecticut’s estate tax.  In Program Manager Technical Advice 2019-03 the IRS looks at the issue of whether the estate tax paid to the state of Connecticut has to be reduced proportionately to account for Connecticut gift taxes paid within three years of death that are included in the Connecticut taxable estate.

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