14 Jan 2025

💼Section 2801 Tax Regulations

Guidance Under Section 2801 Regarding the Imposition of Tax on Certain Gifts and Bequests From Covered Expatriates

Summary

This document contains final regulations that provide guidance on the application of a tax on United States citizens and residents, as well as certain trusts, that receive, directly or indirectly, gifts or bequests from certain individuals who relinquished United States citizenship or ceased to be lawful permanent residents of the United States. The final regulations also provide guidance on the method of reporting and paying this tax. The final regulations primarily affect United States citizens and residents, as well as certain trusts, that receive one or more such gifts or bequests.

Agencies

  • Treasury Department
  • Internal Revenue Service

Business Impact ?

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The regulations outline compliance requirements for U.S. citizens and residents receiving gifts or bequests from covered expatriates, particularly related to tax reporting (Form 708) and the imposition of a Section 2801 tax. The final regulations impact financial planning and compliance practices for businesses, especially trusts involved with expatriate transfers.

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