Illinois Estate Tax Portability & Marital Deduction

No portability — but a state-only QTIP election that, used well, can bring a much larger estate down to zero.

35 ILCS 405/2(b-1); Illinois AG guidance

Quick answer: no portability, but Illinois offers its own, independent QTIP election that can be even more powerful. Get a calibrated estimate in the Illinois estate tax calculator.

Portability, ruled out explicitly

Confirmed current, straight from the Attorney General's own fact sheet: "the portability and carry-over of the unused federal exemption to the surviving spouse is inapplicable to the computation and assessment of the Illinois Estate Tax". A deceased spouse's unused $4,000,000 exclusion simply cannot transfer to the survivor.

The Illinois-only QTIP, and how powerful it can be

For deaths on or after January 1, 2009, an estate may make an Illinois QTIP election independent of any federal QTIP election, deferring Illinois tax on qualifying property passed to a surviving spouse. The Attorney General's own published example shows exactly how far this can reach: a $13,610,000 estate, with a surviving spouse and an Illinois QTIP election of $9,610,000, owes $0 Illinois estate tax — the election brings the taxable amount down to precisely the $4,000,000 exclusion.

It extends to civil unions, unlike federal law

Parties to a civil union recognized under the Illinois Religious Freedom Protection and Civil Union Act are treated the same as spouses for the Illinois marital deduction and QTIP election, even though civil unions aren't recognized for federal estate tax purposes at all. A civil union partner making this election must still file a full set of returns, including a pro forma federal Form 706 completed as if federal law allowed the deduction.

The election must be made correctly on the return

The Illinois QTIP is elected on a timely filed Form 700 by checking the election box, entering the dollar amount, and providing the surviving spouse's Social Security number, along with a list of the specific QTIP property — including the percentage included when the property sits inside a trust.

Facing probate in Illinois?

A local probate attorney can review your estate — many offer a free consultation.

Talk to an Illinois attorney

Because Illinois's underlying tax computation is itself an interrelated calculation (see the threshold and rates guide), the exact benefit of any QTIP election is best confirmed using the Attorney General's own calculator.

Portability & marital deduction — frequently asked questions

Does Illinois offer estate tax portability between spouses?

No. The portability and carry-over of any unused federal exemption to a surviving spouse is inapplicable to the computation and assessment of the Illinois estate tax, per the Attorney General's own guidance.

What does Illinois offer instead of portability?

An Illinois-only QTIP election under 35 ILCS 405/2(b-1), available for deaths on or after January 1, 2009, made independently of any federal QTIP election.

Does the Illinois QTIP election apply to civil unions?

Yes — parties to a civil union recognized under the Illinois Religious Freedom Protection and Civil Union Act are treated the same as spouses for Illinois marital deduction and QTIP purposes, even though civil unions aren't recognized for federal estate tax purposes at all.

Can a large estate reach $0 Illinois tax through the QTIP election alone?

Yes — the Attorney General's own example shows a $13,610,000 estate with a surviving spouse and an Illinois QTIP election of $9,610,000 owing $0 Illinois estate tax, since the election brings the taxable amount down to exactly the $4,000,000 exclusion.

This page provides general guidance only and is not legal or tax advice. Based on 35 ILCS 405/2(b-1) and the Illinois Attorney General's Estate Tax Instruction Fact Sheet. Confirm current figures and planning options with the Illinois Attorney General's office or a licensed estate planning attorney before acting.