Date: 2025-01-14
Links to Federal Register: HTML, PDF
(Proposed Regulation: HTML, PDF)
Document Number: 2025-00284, RIN: 1545-BJ43
Action: Final regulations.
Abstract: 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.
| Notable phrases | Frequency |
|---|---|
| covered gift | 415 |
| section 2801 tax | 284 |
| covered gift(s) and covered bequest(s) | 125 |
| non-electing foreign trust | 108 |
| Form 708 | 88 |
| general power of appointment | 33 |
| treated as a domestic trust | 29 |
| foreign gift or estate tax | 11 |
| received from covered expatriates | 10 |
| Reg. Cites | Frequency |
|---|---|
| 28.2801-2(f) | 9 |
| 28.2801-2(i)(2) | 8 |
| 28.2801-2(e) | 8 |
| 28.2801-5(d) | 7 |
| 28.2801-2(h) | 7 |
| 28.2801-2 | 6 |
| 28.6071-1 | 6 |
| 28.6001-1 | 6 |
| 28.2801-3 | 6 |
| 28.2801-7 | 5 |
| 28.2801-5(e) | 5 |
| 28.6011-1 | 5 |
| 28.2801-4 | 4 |
| 28.6071-1(a) | 4 |
| 28.2801-2(b) | 4 |
| 28.2801-1 | 4 |
| 28.2801-4(e) | 4 |
| 28.2801-6(b) | 4 |
| 28.6091-1 | 4 |
| 28.2801-6(c)(1) | 4 |
| Sec. Cites | Frequency |
|---|---|
| 2801 | 501 |
| 2801(c) | 30 |
| 164 | 13 |
| 2801(e)(3) | 12 |
| 643(i) | 10 |
| 2801(e)(4)(b)(i) | 8 |
| 2503(b) | 7 |
| 6039F | 7 |
| 1015(d) | 7 |
| 2801(e)(4)(b)(ii) | 6 |
| 2041(b)(2) | 6 |
| 7701(a)(30) | 5 |
| 2701 | 5 |
| 6651 | 5 |
| 164(a) | 4 |
| 6048(c) | 4 |
| 2511(a) | 4 |
| 7701(b)(1)(A) | 4 |
| 6694 | 3 |
Statistics
Number of pages: 35, words: 43,030, sentences: 1,468
Average words per sentence: 29