Treasury Regulations (26 C.F.R.)
26 CFR § 20.2208-1
Certain residents of possessions considered citizens of the United States.
As used in this part, the term “citizen of the United States” is considered to include a decedent dying after September 2, 1958, who, at the time of his death, was domiciled in a possession of the United States and was a United States citizen, and who did not acquire his United States citizenship solely by reason of his being a citizen of such possession or by reason of his birth or residence within such possession. The estate of such a decedent is, therefore, subject to the tax imposed by section 2001. See paragraph (a)(2) of § 20.0-1 and § 20.2209-1 for further information relating to the application of the Federal estate tax to the estates of decedents who were residents of possessions of the United States. The application of this section may be illustrated by the following example and the examples set forth in § 20.2209-1:
Example.
A, a citizen of the United States by reason of his birth in the United States at San Francisco, established residence in Puerto Rico and acquired a Puerto Rican citizenship. A died on September 4, 1958, while a citizen and domiciliary of Puerto Rico. A's estate is, by reason of the provisions of section 2208, subject to the tax imposed by section 2001 inasmuch as his United States citizenship is based on birth in the United States and is not based solely on being a citizen of a possession or solely on birth or residence in a possession.
[T.D. 6526, 26 FR 417, Jan. 19, 1961]
Source: view the official text
In this part (40 sections)
- 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…
- 20.6001-1 · Persons required to keep records and render statements.
- 20.6011-1 · General requirement of return, statement, or list.
- 20.6011-4 · Requirement of statement disclosing participation in…
- 20.6018-1 · Returns.
- 20.6018-2 · Returns; person required to file return.
- 20.6018-3 · Returns; contents of returns.
- 20.6018-4 · Returns; documents to accompany the return.
- 20.6036-1 · Notice of qualification as executor of estate of decedent…
- 20.6036-2 · Notice of qualification as executor of estate of decedent…
- 20.6060-1 · Reporting requirements for tax return preparers.
- 20.6061-1 · Signing of returns and other documents.
- 20.6065-1 · Verification of returns.
- 20.6071-1 · Time for filing preliminary notice required by § 20.6036-1.
- 20.6075-1 · Returns; time for filing estate tax return.
- 20.6081-1 · Extension of time for filing the return.
- 20.6091-1 · Place for filing returns or other documents.
- 20.6091-2 · Exceptional cases.
- 20.6107-1 · Tax return preparer must furnish copy of return to taxpayer…