Core goals

• Minimize CT exposure via domicile integrity and situs control.
• Use marital/QTIP planning to defer or reduce state tax (consistent with federal).
• Sequence lifetime gifts mindful of the CT addback and appreciation shifting.
• Secure liquidity for the 6-month payment requirement; consider §6166 leverage.
• Build valuation workpapers aligned to federal schedules.

Who this is for

• CT residents near/over the exemption.
• Nonresidents with CT-situs real/tangible property.
• Executors/advisors coordinating federal 706 and CT filings.

Domicile (resident estates)

• Establish intent with objective ties: home, registrations, community/professional ties.
• Keep evidence consistent across years (returns, licenses, voter/vehicle, doctors/advisors).

Situs (nonresident estates)

• Nonresidents: CT taxes CT real and tangible property; most intangibles follow domicile absent a CT business situs.
• Entity interests are typically intangibles; watch look-through risk where the entity is effectively a CT real/tangible holding vehicle.

Conformity & case law

Connecticut generally follows federal marital-deduction and QTIP rules. In Estate of Brooks (2017), CT confirmed inclusion of QTIP property in the survivor’s CT estate.

• Partial/Clayton QTIP options: coordinate federal & CT elections and statements.
• Portability: no separate CT portability; federal portability remains a federal election.

Design tips

• Draft QTIP terms to meet federal requirements; align trustee powers and accounting for later inclusion.
• Model survivor outcomes by asset mix (CT real/tangible vs. intangibles elsewhere) to manage future CT exposure.

Unified system

• CT taxable gifts since 1/1/2005 are included in the CT computation.
• The state exemption mirrors the federal basic exclusion for the year of death.

Practical implications

• Gifts reduce remaining exemption but can remove post-gift appreciation from both federal & CT estates.
• Use annual-exclusion gifts; direct tuition/medical payments preserve exemption.

Valuation

• Qualified appraisals for CT real/tangible assets; reconcile to federal schedules (706/706-NA).
• Consider valuation discounts where warranted; maintain robust workpapers for DRS.

Liquidity & extensions

• Payment deadline: 6 months after death for taxable estates.
• Extension to file: up to +9 months via CT-706/709 EXT (request by month 6).
• Extension to pay: possible for reasonable cause via CT-706/709 EXT (interest may apply).
• Coordinate federal §6166 (closely held business) with CT payments; include election documentation.

Design & documents

• Will/Revocable Trust with marital/QTIP options (consider Clayton switch).
• Nonresidents: entity/titling review for CT-situs assets; evidence of location & purpose.
• Funding memos; beneficiary designations; durable POA/health docs.

Execution & filings

• Assemble federal attachments (706/706-NA, 712, appraisals) for CT-706/709 or CT-706 NT.
• Calendar the 6-month CT due date; submit EXT forms on time.
• Nontaxable estates: file CT-706 NT with the Probate Court for clearance.