Connecticut General Statutes

Conn. Gen. Stat. § 12-345e (2026)

Tax liability for transfer of property subject to general power of appointment

✓ current as of May 2026
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Nothing contained in sections 12-345b to 12-345e, inclusive, shall be deemed to relieve from taxation, under this chapter, in the estate of the donor of a general power of appointment, the transfer of the property subject to such power. For purposes of computing the rate of taxation under this chapter in the estate of the donor, the property transferred subject to such power shall be deemed to pass to the donee of the power, and the donee of the power shall be deemed to take such property. The provisions of section 12-340 shall apply with respect to any tax imposed by this section.

(1972, P.A. 290, S. 3; P.A. 74-46.)

History: 1972 act effective May 24, 1972, and retroactive to January 1, 1972 (all estates of persons dying before January 1, 1972, are subject to succession tax laws applicable before that date and continued in force for that purpose); P.A. 74-46 added provision clarifying transfer of property from donor to donee.

Statute imposes tax liability on transfer of property which is subject to general power of appointment; the 1974 amendment to section mandated that appointive property be deemed to have passed entirely to donee at his donor's death. 173 C. 232.

Cited. 10 CA 95.

Notes of Decisions
Cited in 2 cases, 1977–1987 · leading case: Tax Comm'r v. Est. of Bissell, 377 A.2d 305 (Conn. 1977).
Tax Comm'r v. Est. of Bissell, 377 A.2d 305 (Conn. 1977). · cites it 9× “General Statutes § 12-345e. 3 In computing this succession tax, the tax commissioner determined that because of the donee’s power to appoint, it was impossible at the date of the donor’s death to ascertain who would ultimately take the property and in what amount.”
Dubno v. Falsey, 521 A.2d 1044 (Conn. App. Ct. 1987). · cites it 6× “Since the taxability of the transfer depends upon statutes in force as of the date of the transfer, however, the recomputation in the present case was done as though General Statutes § 12-345e did not exist.”
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