
QDOT Rules, Rewritten: What Treasury Decision 10050 Means for Business Owners with Non-Citizen Spouses
Treasury Decision 10050, effective July 10, 2026, delivers the first substantial update to Qualified Domestic Trust (QDOT) regulations in three decades. Here is why the unlimited marital deduction excludes non-citizen spouses, what a QDOT requires — a U.S. trustee, an affirmative Form 706 election, and security for trusts over $2 million — and which four procedural fixes the new rules make for business owners' estates.










