On Jan. 14, US IRS issued final rules on tax on gifts from expatriates.
US IRS issued final regulations on tax on US citizens and residents, certain trusts, that receive gifts or bequests from certain individuals who relinquished US citizenship.
Amend subch B of 26 CFR Ch 1 (Estate and Gift Taxes), adding part 28 under section 2801 26 CFR 28 (Imposition of Tax on Gifts, Bequests from Covered Expatriates).
Final Regulations
Ch. 15 consists solely of section 2801, imposes section 2801 tax on certain transfers of property by gift (covered gifts), transfers of property by bequest (covered bequests).
From certain individuals who expatriate on, after Jun. 17, 2008 (covered expatriates).
Provides for exceptions from definitions covered gift and covered bequest any taxable gift by covered expatriate, property included in gross estate of covered expatriate.
If property reported on timely filed gift, estate tax return (timely filed requirement).
Effectiveness
Regulations are effective Jan. 14, 2025.
Generally, depending on regulation section, section applies to covered gifts or covered bequests received on or after Jan. 1, 2025, or section applies on, after Jan. 14, 2025.
