Treasury Regulations (26 C.F.R.)
26 CFR § 20.2101-1
Estates of nonresidents not citizens; tax imposed.
# (a) Imposition of tax.
Section 2101 imposes a tax on the transfer of the taxable estate of a nonresident who is not a citizen of the United States at the time of death. In the case of estates of decedents dying after November 10, 1988, the tax is computed at the same rates as the tax that is imposed on the transfer of the taxable estate of a citizen or resident of the United States in accordance with the provisions of sections 2101(b) and (c). For the meaning of the terms resident, nonresident, and United States, as applied to a decedent for purposes of the estate tax, see § 20.0-1(b)(1) and (2). For the liability of the executor for the payment of the tax, see section 2002. For special rules as to the phaseout of the graduated rates and unified credit, see sections 2001(c)(2) and 2101(b).
# (b) Special rates in the case of certain decedents.
In the case of an estate of a nonresident who was not a citizen of the United States and who died after December 31, 1976, and on or before November 10, 1988, the tax on the nonresident's taxable estate is computed using the formula provided under section 2101(b), except that the rate schedule in paragraph (c) of this section is to be used in lieu of the rate schedule in section 2001(c).
# (c) Rate schedule for decedents dying after December 31, 1976 and on or before November 10, 1988.
| If the amount for which the tentative tax to be computed is: | The tentative tax is: |
|---|---|
| Not over $100,000 | 6% of such amount. |
| Over $100,000 but not over $500,000 | $6,000, plus 12% of excess over $100,000. |
| Over $500,000 but not over $1,000,000 | $54,000, plus 18% of excess over $500,000. |
| Over $1,000,000 but not over $2,000,000 | $144,000, plus 24% of excess over $1,000,000. |
| Over $2,000,000 | $384,000, plus 30% of excess over $2,000,000. |
[T.D. 8612, 60 FR 43551, Aug. 22, 1995]
Source: view the official text
In this part (40 sections)
- 20.2056(c)-1 · (c)-1 Marital deduction; definition of “passed from the…
- 20.2056(c)-2 · (c)-2 Marital deduction; definition of “passed from the…
- 20.2056(c)-3 · (c)-3 Marital deduction; definition of “passed from the…
- 20.2056(d)-1 · (d)-1 Marital deduction; special rules for marital…
- 20.2056(d)-2 · (d)-2 Marital deduction; effect of disclaimers of…
- 20.2056(d)-3 · (d)-3 Marital deduction; effect of disclaimers of…
- 20.2056A-0 · Table of contents.
- 20.2056A-1 · Restrictions on allowance of marital deduction if…
- 20.2056A-2 · Requirements for qualified domestic trust.
- 20.2056A-3 · QDOT election.
- 20.2056A-4 · Procedures for conforming marital trusts and nontrust…
- 20.2056A-5 · Imposition of section 2056A estate tax.
- 20.2056A-6 · Amount of tax.
- 20.2056A-7 · Allowance of prior transfer credit under section 2013.
- 20.2056A-8 · Special rules for joint property.
- 20.2056A-9 · Designated Filer.
- 20.2056A-10 · Surviving spouse becomes citizen after QDOT established.
- 20.2056A-11 · Filing requirements and payment of the section 2056A…
- 20.2056A-12 · Increased basis for section 2056A estate tax paid with…
- 20.2056A-13 · Applicability dates.
- 20.2101-1 · Estates of nonresidents not citizens; tax imposed.
- 20.2102-1 · Estates of nonresidents not citizens; credits against tax.
- 20.2103-1 · Estates of nonresidents not citizens; “entire gross estate”.
- 20.2104-1 · Estates of nonresidents not citizens; property within the…
- 20.2105-1 · Estates of nonresidents not citizens; property without the…
- 20.2106-1 · Estates of nonresidents not citizens; taxable estate;…
- 20.2106-2 · Estates of nonresidents not citizens; deductions for…
- 20.2107-1 · Expatriation to avoid tax.
- 20.2202-1 · Missionaries in foreign service.
- 20.2203-1 · Definition of executor.
- 20.2204-1 · Discharge of executor from personal liability.
- 20.2204-2 · Discharge of fiduciary other than executor from personal…
- 20.2204-3 · Special rules for estates of decedents dying after December…
- 20.2205-1 · Reimbursement out of estate.
- 20.2206-1 · Liability of life insurance beneficiaries.
- 20.2207-1 · Liability of recipient of property over which decedent had…
- 20.2207A-1 · Right of recovery of estate taxes in the case of certain…
- 20.2207A-2 · Effective date.
- 20.2208-1 · Certain residents of possessions considered citizens of the…
- 20.2209-1 · Certain residents of possessions considered nonresidents…