§ 28.2801-1. Tax on certain gifts and bequests from covered expatriates.
168 words·~1 min read·
/us/cfr/t26/s§ 28.2801-1·A research copy — for the controlling text, always check the official state or federal source. Not legal advice.
(a)In general. Section 2801 of the Internal Revenue Code
(Code)imposes a tax (section 2801 tax) on covered gifts and covered bequests, including distributions attributable to covered gifts and covered bequests from non-electing foreign trusts, received by a U.S. citizen or resident from a covered expatriate during a calendar year. Domestic trusts, as well as electing foreign trusts, are subject to tax under section 2801 in the same manner as if the trusts were U.S. citizens. See section 2801(e)(4)(A)(i) and (B)(iii). Accordingly, the section 2801 tax is paid by the U.S. citizen or resident, domestic trust, or electing foreign trust that receives the covered gift or covered bequest, including distributions attributable to covered gifts and covered bequests from non-electing foreign trusts. For purposes of the regulations in this part 28 (26 CFR part 28), references to U.S. citizens are considered to include domestic trusts and electing foreign trusts.
(b)Applicability date. This section applies to covered gifts or covered bequests received on or after January 1, 2025.
Connections1 off-index
1 reference not yet in our index
- 26 CFR 28
Citation graph
cites case law
§ 28.2801-1
Tax on certain gifts and bequests from covered expatriates.
Cite26 CFR 28
Cites 1Cited by 0 across 0 sources