Which of the following are true concerning a qualified domestic trust (QDOT)?

1. It is common for the surviving spouse to receive an income interest in the trust.

2. It is designed to capture the marital deduction for a non-U.S. citizen spouse.

3. Generally, distributions to the surviving spouse, other than income, will be subjected to the estate tax at S1's cumulative marginal rates.

4. The trust can qualify for the marital deduction even if it is established after the first spouse dies.

Please Explain.

A. (1), (2), and (3) only are correct.

B. (2) and (4) only are correct.

C. (1) and (3) only are correct.

D. (4) only is correct.

E. All are correct.