No interest in a qualified tuition program is includable in the estate of any individual for purposes of the estate tax, with two exceptions: (1) distributions made to the estate of the beneficiary upon the beneficiary’s death; and (2) if such a donor dies before the end of a five-year gift tax proration period (see Q 902), the gross estate of the donor will include the portion of contributions allocable to periods after the death of the donor.1
See Q 902 for the gift tax treatment and Q 687 for the income tax treatment of qualified tuition programs.
1. IRC § 529(c)(4).