50 States + D.C. coverage 2026 $15M federal exemption Statute-cited figures Updated 2026

Late Portability Election Eligibility Checker

Missed the estate tax return that elects portability? IRS Rev. Proc. 2022-32 lets a surviving spouse’s executor make the election late — but only within a strict window. Enter the facts to see whether the simplified method still applies and the deadline.

This checker applies the simplified late-election rules of IRS Rev. Proc. 2022-32 only. It does not compute the DSUE amount (that depends on the decedent’s applicable exclusion for the year of death minus lifetime taxable gifts and the taxable estate). Confirm eligibility and amounts with the IRS or a licensed estate attorney or CPA before filing.

Informal estimate only — not legal or tax advice. Figures cite federal statute (IRC § 2010, OBBBA 2025) and each state's Department of Revenue. Tax laws and exemption amounts change yearly; confirm the current rule with the IRS, your state agency, or a licensed estate attorney or CPA before relying on any number.

How this calculator works

The late portability election lets the executor of a deceased spouse’s estate file Form 706 solely to pass the decedent’s unused exclusion (DSUE) to the surviving spouse, even though the normal nine-month deadline has passed. Under Rev. Proc. 2022-32 (effective July 8, 2022), the simplified method extends the deadline to the fifth anniversary of the decedent’s date of death. This checker tests the six eligibility conditions and shows the deadline.

Calculation method & sources

  • Governing authority: IRS Rev. Proc. 2022-32 (effective July 8, 2022) supersedes Rev. Proc. 2017-34. It is the exclusive simplified procedure for obtaining § 301.9100-3 relief to elect portability under § 2010(c)(5)(A) within five years of death.
  • Eligibility gate: The decedent must have died after Dec. 31, 2010, been a U.S. citizen or resident at death, been survived by a spouse, not have been otherwise required to file Form 706 under § 6018(a), and the executor must not have timely filed Form 706.
  • Deadline: A complete Form 706 stating “FILED PURSUANT TO REV. PROC. 2022-32 TO ELECT PORTABILITY UNDER § 2010(c)(5)(A)” must be filed on or before the fifth anniversary of the decedent’s date of death.
  • DSUE amount: The DSUE equals the decedent’s applicable exclusion for the year of death minus lifetime taxable gifts and the taxable estate. In 2026 the per-person federal exemption is $15,000,000. This tool does not compute the amount — enter your expected DSUE if you have it.

How to interpret your late portability election result

  • “Eligible — file before the 5th anniversary” means the simplified method applies and the deadline is shown.
  • “Deadline missed” means the fifth anniversary has passed; simplified relief is closed (and for pre-July-8-2017 deaths there is no remedy under this procedure).
  • If the estate was required to file Form 706, the portability deadline was statutory and Rev. Proc. 2022-32 does not provide relief.
  • A timely filed Form 706 generally made the election automatically; a late election is only for estates that did not timely file.

Related guides

Frequently asked questions

What is a late portability election?
It is using IRS Rev. Proc. 2022-32 to file Form 706 after the normal deadline solely to elect portability of a deceased spouse’s unused exclusion (DSUE), so the surviving spouse can add it to their own exclusion.
How long do I have to make the late election?
Under Rev. Proc. 2022-32, the executor must file a complete Form 706 on or before the fifth anniversary of the decedent’s date of death. The prior two-year window (Rev. Proc. 2017-34) was replaced.
Who qualifies for the simplified method?
The decedent must have died after Dec. 31, 2010, been a U.S. citizen or resident at death, been survived by a spouse, and the estate must not have been otherwise required to file Form 706. The executor also must not have timely filed.
What if the estate was required to file Form 706?
If the estate was independently required to file under § 6018(a), the portability deadline was statutory and Rev. Proc. 2022-32 relief is not available. In that case the election should have been made on the timely return.
Does the late election extend the surviving spouse’s refund window?
No. Rev. Proc. 2022-32 does not extend the time for the surviving spouse to claim a credit or refund of overpaid gift or estate tax; protective claims should be filed within the normal § 6511(a) period.
Not legal or tax advice. This estimate follows the federal and state statutes referenced on this page but cannot capture every factor (trusts, business valuation, charitable deductions, prior gifts, state add-backs).

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