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Portability

Husband 1 (H1) dies in January of 2011, survived by Wife (W). Neither has made any taxable gifts during H1's lifetime. H1's executor elects portability of H1's timely filed estate tax return. H1 dies without assets and the DSUE amount of H1 as computed on the estate tax return filed on behalf of H1's estate is $5 million. On Dec. 31, 2011, W makes taxable gifts to her children valued at $3 million (ignore Section 2503 exclusion W used it already for birthday gifts). W reports the gifts on a timely filed gift tax return. W owes no gift tax. After the death of H1, W marries Husband 2 (H2) in May of 2012. Unfortunately, H2 dies in June 2013. H2's executor elects portability of H2's DSUE amount, which is properly computed on H 2's estate tax return to be $4 million (this is the DSUE amount, which means he had some estate in 2013, assume his kids from prior marriage were the beneficiaries of that estate). W dies in January of 2023 with an estate of $25,000,000.

What is W's AEA that can be applied against her estate when she dies?

2. Husband 1 (H1) dies in January of 2011, survived by Wife (W). Neither has made any taxable gifts during Hl 's lifetime. Hl's executor elects portability of H1's timely filed estate tax return. H1 dies without assets and the DSUE amount of H1 as computed on the estate tax return filed on behalf of H1's estate is $5 million. On Dec. 31, 2011, W makes taxable gifts to her children valued at $3 million (ignore Section 2503 exclusion W used it already for birthday gifts). W reports the gifts on a timely filed gift tax return. W owes no gift tax. After the death of H1, W marries Husband 2 (H2) in May of 2012. Unfortunately, H2 dies in June 2013. H2's executor elects portability of H2's DSUE amount, which is properly computed on H 2 's estate tax return to be $4 million (this is the DSUE amount, which means he had some estate in 2013, assume his kids from prior marriage were the beneficiaries of that estate). W dies in January of 2023 with an estate of $25,000,000. What is W's AEA that can be applied against her estate when she dies? 2. Husband 1 (H1) dies in January of 2011, survived by Wife (W). Neither has made any taxable gifts during Hl 's lifetime. Hl's executor elects portability of H1's timely filed estate tax return. H1 dies without assets and the DSUE amount of H1 as computed on the estate tax return filed on behalf of H1's estate is $5 million. On Dec. 31, 2011, W makes taxable gifts to her children valued at $3 million (ignore Section 2503 exclusion W used it already for birthday gifts). W reports the gifts on a timely filed gift tax return. W owes no gift tax. After the death of H1, W marries Husband 2 (H2) in May of 2012. Unfortunately, H2 dies in June 2013. H2's executor elects portability of H2's DSUE amount, which is properly computed on H 2 's estate tax return to be $4 million (this is the DSUE amount, which means he had some estate in 2013, assume his kids from prior marriage were the beneficiaries of that estate). W dies in January of 2023 with an estate of $25,000,000. What is W's AEA that can be applied against her estate when she dies

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