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Well, the phrase portability exemption means that another individual can use your exemption if you die not using it either during your lifetime or at death. For federal purposes, there’s portability between a husband and a wife. So if a wife dies and doesn’t use any of her exemption, so long as her executer files an estate tax return and elects portability, her surviving husband will be able to use her unused exemption.
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New York tax and estate planning attorney Carlyn McCaffrey of McDermott Will & Emery explains “portability of exemption.”