Imposition
Except as provided in section 2107, a tax is hereby imposed on the transfer of the taxable estate (determined as provided in section 2106) of every decedent nonresident not a citizen of the United States.
Computation of tax
Adjustments for taxable gifts
Adjusted taxable gifts defined
For purposes of this section, the term “adjusted taxable gifts” means the total amount of the taxable gifts (within the meaning of section 2503 as modified by section 2511) made by the decedent after , other than gifts which are includible in the gross estate of the decedent.
Adjustment for certain gift tax
For purposes of this section, the rules of section 2001(d) shall apply.
Aug. 16, 1954, ch. 73668A Stat. 397Pub. L. 89–809, title I, § 108(a)80 Stat. 1571Pub. L. 94–455, title XX, § 2001(c)(1)(D)90 Stat. 1850Pub. L. 100–647, title V, § 5032(a)102 Stat. 3669Pub. L. 101–239, title VII, § 7815(c)103 Stat. 2415Pub. L. 103–66, title XIII, § 13208(b)(3)107 Stat. 469Pub. L. 107–147, title IV, § 411(g)(2)116 Stat. 46(, ; , , ; , , ; , (c), , ; , , ; , , ; , , .)
Editorial Notes
Amendments
Pub. L. 107–1472002—Subsec. (b). struck out concluding provisions which read as follows: “For purposes of the preceding sentence, there shall be appropriate adjustments in the application of section 2001(c)(2) to reflect the difference between the amount of the credit provided under section 2102(c) and the amount of the credit provided under section 2010.”
Pub. L. 103–661993—Subsec. (b). substituted “section 2001(c)(2)” for “section 2001(c)(3)” in last sentence.
Pub. L. 101–2391989—Subsec. (b). inserted at end “For purposes of the preceding sentence, there shall be appropriate adjustments in the application of section 2001(c)(3) to reflect the difference between the amount of the credit provided under section 2102(c) and the amount of the credit provided under section 2010.”
Pub. L. 100–647, § 5032(a)1988—Subsec. (b). , substituted “a tentative tax computed under section 2001(c)” for “a tentative tax computed in accordance with the rate schedule set forth in subsection (d)” in pars. (1) and (2).
Pub. L. 100–647, § 5032(c)Subsec. (d). , struck out subsec. (d) which provided a rate schedule.
Pub. L. 94–4551976— redesignated existing provisions as (a) to (d), inserted provisions for adjustments for taxable gifts, revised the tax rate schedule, and struck out provisions relating to property held by Alien Property Custodian.
Pub. L. 89–8091966—Subsec. (a). substituted table to be used in computing the tax imposed on transfer of taxable estate, determined as provided in section 2106, of every decedent nonresident not a citizen of the United States for provisions sending taxpayer to table in section 2001 for computation of tax imposed.
Statutory Notes and Related Subsidiaries
Effective Date of 2002 Amendment
Pub. L. 107–147Pub. L. 107–16section 411(x) of Pub. L. 107–147section 25B of this titleAmendment by effective as if included in the provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001, , to which such amendment relates, see , set out as a note under .
Effective Date of 1993 Amendment
Pub. L. 103–66section 13208(c) of Pub. L. 103–66section 2001 of this titleAmendment by applicable in the case of decedents dying and gifts made after , see , set out as a note under .
Effective Date of 1989 Amendment
Pub. L. 101–239Pub. L. 100–647section 7817 of Pub. L. 101–239section 1 of this titleAmendment by effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, , to which such amendment relates, see , set out as a note under .
Effective Date of 1988 Amendment
Pub. L. 100–647, title V, § 5032(d)102 Stat. 3670
Effective Date of 1976 Amendment
Pub. L. 94–455section 2001(d)(1) of Pub. L. 94–455section 2001 of this titleAmendment by applicable to estates of decedents dying after , see , set out as a note under .
Effective Date of 1966 Amendment
Pub. L. 89–809, title I, § 108(i)80 Stat. 1574