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Summary of the Law on Gifts From a Non-U.S. Taxpayer

December, 2015

A transfer of real property or tangible personal property by a nonresident alien is subject to gift tax only if it is situated in the U.S. Internal Revenue Code Section §2511(a); Regs. §25.2511-3(a). Section 2511 (a) reads as follows:

…, the tax imposed by section 2501 shall apply … whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; but in the case of a nonresident not a citizen of the United States, shall apply to a transfer only if the property is situated within the United States. (emphasis added)

IRC Regulation 25.2511-3 reads as follows:

(a) In general. Section… 2511 contain[s] rules relating to the taxation of transfers of property by gift by a donor who is a nonresident not a citizen of the United States. … these rules are:

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