A QDOT is a qualified domestic trust that is used to allow an non-U.S. citizen who is the spouse of a U.S. citizen to qualify for the unlimited marital deduction that keeps estates from being subject to federal taxes when they are passed to a spouse. In order to protect the spouse that is not a U.S. citizen a QDOT is set up; however, it must meet certain qualifications such as one spouse being a U.S. citizen. If the trust that is being set up, the QDOT, is to have more than 2 million dollars it must be held in a U.S. bank with the bank being the trustee. The trust cannot make any distributions except for income purposes. The exception to the distribution occurs if the trustee is a U.S. citizen or corporation and has to withhold estate taxes.