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Type of trust established for the purpose of permitting the federal estate marital deduction for assets transferred from the decedent's estate to a surviving spouse who is not a citizen of the United States. The trustee for this trust must be a United States corporation or citizen, and if the assets are in excess of $2,000,000, the trustee must be a United States bank. Income from this trust can be distributed to the surviving spouse without incurring any estate tax consequences; however, any distributions of principal are subject to the federal estate tax. Upon the death of the surviving spouse and/or termination of the trust, the distributed principal of the trust is subject to federal estate tax.