Legal corpus: the complete U.S. Code (59,740 sections, all 53 titles)

Ingested titles 12–51 and 54 from OLRC USLM XML @119-100 (the whole Code
now, uniform edition; Title 53 is reserved/empty). LegalText 11,221 ->
59,740; repo total 105,704 records. Deterministic (byte-identical rerun,
verified on Title 42's 8,356 sections); make check green. make
legal-us-code default now covers every title.

Co-Authored-By: Claude Opus 4.8 <noreply@anthropic.com>

legal/us/code/title-26/chapter-11/section-2002.md

@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2002"
+description: "Liability for payment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2002"
+citation: "26 U.S.C. § 2002"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2002"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "800e20fb8f9e45b65e779ff0c23a5ca9f22357028fad08bd44dab8164374e406"
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+text_hash: "96eb7ef5afcb7d89a0a051a636f9f72081722111885a7f5963fc2898fbec0a41"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2002 - Liability for payment
+
+## Text
+
+The tax imposed by this chapter shall be paid by the executor.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 374; Pub. L. 98–369, div. A, title V, § 544(b)(1), July 18, 1984, 98 Stat. 894; Pub. L. 101–239, title VII, § 7304(b)(2)(A), Dec. 19, 1989, 103 Stat. 2353.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1989—Pub. L. 101–239 substituted “The” for “Except as provided in section 2210, the”. 1984—Pub. L. 98–369 inserted exception phrase.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1989 AmendmentPub. L. 101–239, title VII, § 7304(b)(3), Dec. 19, 1989, 103 Stat. 2353, provided that: “The amendments made by this subsection [amending this section and section 6018 of this title and repealing section 2210 of this title] shall apply to estates of decedents dying after July 12, 1989.”
+
+Effective Date of 1984 AmendmentPub. L. 98–369, div. A, title V, § 544(d), July 18, 1984, 98 Stat. 894, provided that: “The amendments made by this section [enacting section 2210 of this title and amending this section and sections 6018 and 6166 of this title] shall apply to those estates of decedents which are required to file returns on a date (including any extensions) after the date of enactment of this Act [July 18, 1984].”

legal/us/code/title-26/chapter-11/section-2010.md

@@ -0,0 +1,101 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2010"
+description: "Unified credit against estate tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2010"
+citation: "26 U.S.C. § 2010"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2010"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "1e7c4d3024f8e15b17966e33da4547c6d4b05e1f7525cde2049d7cbaecb30903"
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+text_hash: "72fe4f0e1ff31ba6d231f0688ab339284a1cff672c9fbe88e2fc86773fdfb7eb"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2010 - Unified credit against estate tax
+
+## Text
+
+(a) General rule A credit of the applicable credit amount shall be allowed to the estate of every decedent against the tax imposed by section 2001.
+
+(b) Adjustment to credit for certain gifts made before 1977 The amount of the credit allowable under subsection (a) shall be reduced by an amount equal to 20 percent of the aggregate amount allowed as a specific exemption under section 2521 (as in effect before its repeal by the Tax Reform Act of 1976) with respect to gifts made by the decedent after September 8, 1976.
+
+(c) Applicable credit amount (1) In general For purposes of this section, the applicable credit amount is the amount of the tentative tax which would be determined under section 2001(c) if the amount with respect to which such tentative tax is to be computed were equal to the applicable exclusion amount.
+
+(2) Applicable exclusion amount For purposes of this subsection, the applicable exclusion amount is the sum of—
+
+(A) the basic exclusion amount, and
+
+(B) in the case of a surviving spouse, the deceased spousal unused exclusion amount.
+
+(3) Basic exclusion amount (A) In general For purposes of this subsection, the basic exclusion amount is $15,000,000.
+
+(B) Inflation adjustment In the case of any decedent dying in a calendar year after 2026, the dollar amount in subparagraph (A) shall be increased by an amount equal to—
+
+(i) such dollar amount, multiplied by
+
+(ii) the cost-of-living adjustment determined under section 1(f)(3) for such calendar year by substituting “calendar year 2025” for “calendar year 2016” in subparagraph (A)(ii) thereof.
+
+If any amount as adjusted under the preceding sentence is not a multiple of $10,000, such amount shall be rounded to the nearest multiple of $10,000.
+
+(4) Deceased spousal unused exclusion amount For purposes of this subsection, with respect to a surviving spouse of a deceased spouse dying after December 31, 2010, the term “deceased spousal unused exclusion amount” means the lesser of—
+
+(A) the basic exclusion amount, or
+
+(B) the excess of—
+
+(i) the applicable exclusion amount of the last such deceased spouse of such surviving spouse, over
+
+(ii) the amount with respect to which the tentative tax is determined under section 2001(b)(1) on the estate of such deceased spouse.
+
+(5) Special rules (A) Election required A deceased spousal unused exclusion amount may not be taken into account by a surviving spouse under paragraph (2) unless the executor of the estate of the deceased spouse files an estate tax return on which such amount is computed and makes an election on such return that such amount may be so taken into account. Such election, once made, shall be irrevocable. No election may be made under this subparagraph if such return is filed after the time prescribed by law (including extensions) for filing such return.
+
+(B) Examination of prior returns after expiration of period of limitations with respect to deceased spousal unused exclusion amount Notwithstanding any period of limitation in section 6501, after the time has expired under section 6501 within which a tax may be assessed under chapter 11 or 12 with respect to a deceased spousal unused exclusion amount, the Secretary may examine a return of the deceased spouse to make determinations with respect to such amount for purposes of carrying out this subsection.
+
+(6) Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out this subsection.
+
+(d) Limitation based on amount of tax The amount of the credit allowed by subsection (a) shall not exceed the amount of the tax imposed by section 2001.
+
+(Added Pub. L. 94–455, title XX, § 2001(a)(2), Oct. 4, 1976, 90 Stat. 1848; amended Pub. L. 97–34, title IV, § 401(a)(1), (2)(A), Aug. 13, 1981, 95 Stat. 299; Pub. L. 101–508, title XI, § 11801(a)(39), (c)(19)(A), Nov. 5, 1990, 104 Stat. 1388–521, 1388–528; Pub. L. 105–34, title V, § 501(a)(1)(A), (B), Aug. 5, 1997, 111 Stat. 845; Pub. L. 107–16, title V, § 521(a), June 7, 2001, 115 Stat. 71; Pub. L. 111–312, title III, §§ 302(a)(1), 303(a), Dec. 17, 2010, 124 Stat. 3301, 3302; Pub. L. 112–240, title I, § 101(c)(2), Jan. 2, 2013, 126 Stat. 2318; Pub. L. 115–97, title I, §§ 11002(d)(1)(CC), 11061(a), Dec. 22, 2017, 131 Stat. 2060, 2091; Pub. L. 119–21, title VII, § 70106(a), July 4, 2025, 139 Stat. 162.)
+
+## Notes
+
+Inflation Adjusted Items for Certain YearsFor inflation adjustment of certain items in this section, see Revenue Procedures listed in a table under section 1 of this title.
+
+Editorial Notes
+
+References in TextThe Tax Reform Act of 1976, referred to in subsec. (b), is Pub. L. 94–455, Oct. 4, 1976, 90 Stat. 1520. For complete classification of this Act to the Code, see Tables. Section 2521 of this title, referred to in subsec. (b), was repealed by section 2001(b)(3) of Pub. L. 94–455, applicable to gifts made after Dec. 31, 1976.
+
+Amendments2025—Subsec. (c)(3)(A). Pub. L. 119–21, § 70106(a)(1), substituted “$15,000,000” for “$5,000,000”. Subsec. (c)(3)(B). Pub. L. 119–21, § 70106(a)(2)(A), substituted “2026” for “2011” in introductory provisions. Subsec. (c)(3)(B)(ii). Pub. L. 119–21, § 70106(a)(2)(B), substituted “calendar year 2025” for “calendar year 2010”. Subsec. (c)(3)(C). Pub. L. 119–21, § 70106(a)(3), struck out subpar. (C). Text read as follows: “In the case of estates of decedents dying or gifts made after December 31, 2017, and before January 1, 2026, subparagraph (A) shall be applied by substituting ‘$10,000,000’ for ‘$5,000,000’.” 2017—Subsec. (c)(3)(B)(ii). Pub. L. 115–97, § 11002(d)(1)(CC), substituted “for ‘calendar year 2016’ in subparagraph (A)(ii)” for “for ‘calendar year 1992’ in subparagraph (B)”. Subsec. (c)(3)(C). Pub. L. 115–97, § 11061(a), added subpar. (C). 2013—Subsec. (c)(4)(B)(i). Pub. L. 112–240 substituted “applicable exclusion amount” for “basic exclusion amount”. 2010—Subsec. (c). Pub. L. 111–312, § 302(a)(1), amended subsec. (c) generally, substituting pars. (1) and (2) for text which provided that the applicable credit amount for purposes of this section was the amount of the tentative tax which would be determined under the rate schedule set forth in section 2001(c) if the amount with respect to which such tentative tax was to be computed were the applicable exclusion amount determined in accordance with the table, covering years 2002 to 2009, included in that text. Subsec. (c)(2) to (6). Pub. L. 111–312, § 303(a), added pars. (2) to (6) and struck out former par. (2). Prior to amendment, text of par. (2) read as follows: “(A) In general.—For purposes of this subsection, the applicable exclusion amount is $5,000,000. “(B) Inflation adjustment.—In the case of any decedent dying in a calendar year after 2011, the dollar amount in subparagraph (A) shall be increased by an amount equal to— “(i) such dollar amount, multiplied by “(ii) the cost-of-living adjustment determined under section 1(f)(3) for such calendar year by substituting ‘calendar year 2010’ for ‘calendar year 1992’ in subparagraph (B) thereof. If any amount as adjusted under the preceding sentence is not a multiple of $10,000, such amount shall be rounded to the nearest multiple of $10,000.” 2001—Subsec. (c). Pub. L. 107–16, in table, substituted provision that in the case of estates of decedents dying during the years 2002 and 2003, the years 2004 and 2005, the years 2006, 2007, and 2008, and the year 2009, the applicable exclusion amount is $1,000,000, $1,500,000, $2,000,000, and $3,500,000, respectively, for provision that in the case of decedents dying, and gifts made, during the year 1998, the year 1999, the years 2000 and 2001, the years 2002 and 2003, the year 2004, the year 2005, and the year 2006 or thereafter, the applicable exclusion amount is $625,000, $650,000, $675,000, $700,000, $850,000, $950,000, and $1,000,000, respectively. 1997—Subsec. (a). Pub. L. 105–34, § 501(a)(1)(A), substituted “the applicable credit amount” for “$192,800”. Subsecs. (c), (d). Pub. L. 105–34, § 501(a)(1)(B), added subsec. (c) and redesignated former subsec. (c) as (d). 1990—Subsecs. (b) to (d). Pub. L. 101–508 redesignated subsecs. (c) and (d) as (b) and (c), respectively, and struck out former subsec. (b) which provided for a phase-in of the unified credit against estate tax. 1981—Subsec. (a). Pub. L. 97–34, § 401(a)(1), substituted “$192,800” for “$47,000”. Subsec. (b). Pub. L. 97–34, § 401(a)(2)(A), struck out “$47,000” before “credit” from heading and in text substituted in subsec. (a) substitutions for “$192,800” amounts of “$62,800”, “$79,300”, “$96,300”, “$121,800”, and “$155,800” in the case of decedents dying in 1982, 1983, 1984, 1985, and 1986, respectively, for subsec. (a) substitutions for “$47,000” amounts of “$30,000”, “$34,000”, “$38,000”, and “$42,500” in the case of decedents dying in 1977, 1978, 1979, and 1980, respectively.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2025 AmendmentPub. L. 119–21, title VII, § 70106(b), July 4, 2025, 139 Stat. 162, provided that: “The amendments made by this section [amending this section] shall apply to estates of decedents dying and gifts made after December 31, 2025.”
+
+Effective Date of 2017 AmendmentAmendment by section 11002(d)(1)(CC) of Pub. L. 115–97 applicable to taxable years beginning after Dec. 31, 2017, see section 11002(e) of Pub. L. 115–97, set out as a note under section 1 of this title. Amendment by section 11061(a) of Pub. L. 115–97 applicable to estates of decedents dying and gifts made after Dec. 31, 2017, see section 11061(c) of Pub. L. 115–97, set out as a note under section 2001 of this title.
+
+Effective Date of 2013 AmendmentAmendment by Pub. L. 112–240 effective as if included in the amendments made by section 303 of the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010, Pub. L. 111–312, see section 101(c)(3)(B) of Pub. L. 112–240, set out as a note under section 2001 of this title.
+
+Effective Date of 2010 AmendmentAmendment by section 302(a)(1) of Pub. L. 111–312 applicable to estates of decedents dying, generation-skipping transfers, and gifts made, after Dec. 31, 2009, see section 302(f) of Pub. L. 111–312, set out as a note under section 2001 of this title. Pub. L. 111–312, title III, § 303(c), Dec. 17, 2010, 124 Stat. 3303, provided that: “(1) In general.—Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 2505, 2631, and 6018 of this title] shall apply to estates of decedents dying and gifts made after December 31, 2010. “(2) Conforming amendment relating to generation-skipping transfers.—The amendment made by subsection (b)(2) [amending section 2631 of this title] shall apply to generation-skipping transfers after December 31, 2010.”
+
+Effective Date of 2001 AmendmentPub. L. 107–16, title V, § 521(e), June 7, 2001, 115 Stat. 72, provided that: “(1) In general.—Except as provided in paragraphs (2) and (3), the amendments made by this section [amending this section and sections 2057, 2505, and 2631 of this title] shall apply to estates of decedents dying, and gifts made, after December 31, 2001. “(2) Subsection (b)(2).—The amendments made by subsection (b)(2) [amending section 2505 of this title] shall apply to gifts made after December 31, 2009. “(3) Subsections (c) and (d).—The amendments made by subsections (c) and (d) [amending sections 2057 and 2631 of this title] shall apply to estates of decedents dying, and generation-skipping transfers, after December 31, 2003.”
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 applicable to estates of decedents dying, and gifts made, after Dec. 31, 1997, see section 501(f) of Pub. L. 105–34, set out as a note under section 2001 of this title.
+
+Effective Date of 1981 AmendmentPub. L. 97–34, title IV, § 401(c)(1), Aug. 13, 1981, 95 Stat. 300, provided that: “The amendments made by subsection (a) [amending this section and section 6018 of this title] shall apply to the estates of decedents dying after December 31, 1981”.
+
+Savings ProvisionFor provisions that nothing in amendment by Pub. L. 101–508 be construed to affect treatment of certain transactions occurring, property acquired, or items of income, loss, deduction, or credit taken into account prior to Nov. 5, 1990, for purposes of determining liability for tax for periods ending after Nov. 5, 1990, see section 11821(b) of Pub. L. 101–508, set out as a note under section 45K of this title.

legal/us/code/title-26/chapter-11/section-2011.md

@@ -0,0 +1,37 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2011"
+description: "Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(95)(A)(i), Dec. 19, 2014, 128 Stat. 4051]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2011"
+citation: "26 U.S.C. § 2011"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2011"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "347783c3ab24e05a89a5b1d818f64aaa1439cf4ac0ff5e415396a4295e142d84"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "dc90c3c3eb4812127ee5428b6be49b3613cd026ecabdd5aa23df86b6b7e3da65"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2011 - Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(95)(A)(i), Dec. 19, 2014, 128 Stat. 4051]
+
+## Notes
+
+Section, act Aug. 16, 1954, ch. 736, 68A Stat. 374; Feb. 20, 1956, ch. 63, § 3, 70 Stat. 24; Pub. L. 85–866, title I, §§ 65(a), 102(c)(1), Sept. 2, 1958, 72 Stat. 1657, 1674; Pub. L. 86–175, § 3, Aug. 21, 1959, 73 Stat. 397; Pub. L. 94–455, title XIX, §§ 1902(a)(12)(B), 1906(b)(13)(A), title XX, §§ 2001(c)(1)(A), 2004(f)(3), Oct. 4, 1976, 90 Stat. 1806, 1834, 1849, 1872; Pub. L. 97–34, title IV, § 422(e)(2), Aug. 13, 1981, 95 Stat. 316; Pub. L. 107–16, title V, §§ 531(a), 532(a), June 7, 2001, 115 Stat. 72, 73; Pub. L. 107–134, title I, § 103(b)(1), Jan. 23, 2002, 115 Stat. 2431, related to credit for State death taxes.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as an Effective Date of 2014 Amendment note under section 1 of this title.

legal/us/code/title-26/chapter-11/section-2012.md

@@ -0,0 +1,71 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2012"
+description: "Credit for gift tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2012"
+citation: "26 U.S.C. § 2012"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2012"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "ff3f9a0f8d66979c62a00e3308fa99ebd5efb3d4b551f193759343f28df15e74"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "57f6fff0c7f31d3a4cddf4a1fafcfed20e5f71c328cf2cd73c62e13cead3507d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2012 - Credit for gift tax
+
+## Text
+
+(a) In general If a tax on a gift has been paid under chapter 12 (sec. 2501 and following), or under corresponding provisions of prior laws, and thereafter on the death of the donor any amount in respect of such gift is required to be included in the value of the gross estate of the decedent for purposes of this chapter, then there shall be credited against the tax imposed by section 2001 the amount of the tax paid on a gift under chapter 12, or under corresponding provisions of prior laws, with respect to so much of the property which constituted the gift as is included in the gross estate, except that the amount of such credit shall not exceed an amount which bears the same ratio to the tax imposed by section 2001 (after deducting from such tax the unified credit provided by section 2010) as the value (at the time of the gift or at the time of the death, whichever is lower) of so much of the property which constituted the gift as is included in the gross estate bears to the value of the entire gross estate reduced by the aggregate amount of the charitable and marital deductions allowed under sections 2055, 2056, and 2106(a)(2).
+
+(b) Valuation reductions In applying, with respect to any gift, the ratio stated in subsection (a), the value at the time of the gift or at the time of the death, referred to in such ratio, shall be reduced—
+
+(1) by such amount as will properly reflect the amount of such gift which was excluded in determining (for purposes of section 2503(a)), or of corresponding provisions of prior laws, the total amount of gifts made during the calendar quarter (or calendar year if the gift was made before January 1, 1971) in which the gift was made;
+
+(2) if a deduction with respect to such gift is allowed under section 2056(a) (relating to marital deduction), then by the amount of such value, reduced as provided in paragraph (1); and
+
+(3) if a deduction with respect to such gift is allowed under sections 2055 or 2106(a)(2) (relating to charitable deduction), then by the amount of such value, reduced as provided in paragraph (1) of this subsection.
+
+(c) Where gift considered made one-half by spouse Where the decedent was the donor of the gift but, under the provisions of section 2513, or corresponding provisions of prior laws, the gift was considered as made one-half by his spouse—
+
+(1) the term “the amount of the tax paid on a gift under chapter 12”, as used in subsection (a), includes the amounts paid with respect to each half of such gift, the amount paid with respect to each being computed in the manner provided in subsection (d); and
+
+(2) in applying, with respect to such gift, the ratio stated in subsection (a), the value at the time of the gift or at the time of the death, referred to in such ratio, includes such value with respect to each half of such gift, each such value being reduced as provided in paragraph (1) of subsection (b).
+
+(d) Computation of amount of gift tax paid (1) Amount of tax For purposes of subsection (a), the amount of tax paid on a gift under chapter 12, or under corresponding provisions of prior laws, with respect to any gift shall be an amount which bears the same ratio to the total tax paid for the calendar quarter (or calendar year if the gift was made before January 1, 1971) in which the gift was made as the amount of such gift bears to the total amount of taxable gifts (computed without deduction of the specific exemption) for such quarter or year.
+
+(2) Amount of gift For purposes of paragraph (1), the “amount of such gift” shall be the amount included with respect to such gift in determining (for the purposes of section 2503(a), or of corresponding provisions of prior laws) the total amount of gifts made during such quarter or year, reduced by the amount of any deduction allowed with respect to such gift under section 2522, or under corresponding provisions of prior laws (relating to charitable deduction), or under section 2523 (relating to marital deduction).
+
+(e) Section inapplicable to gifts made after December 31, 1976 No credit shall be allowed under this section with respect to the amount of any tax paid under chapter 12 on any gift made after December 31, 1976.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 375; Pub. L. 91–614, title I, § 102(d)(2), Dec. 31, 1970, 84 Stat. 1841; Pub. L. 94–455, title XIX, § 1902(a)(1), title XX, § 2001(a)(3), (c)(1)(B), Oct. 4, 1976, 90 Stat. 1804, 1848, 1850; Pub. L. 97–34, title IV, § 403(a)(2)(A), Aug. 13, 1981, 95 Stat. 301; Pub. L. 107–16, title V, § 532(c)(1), June 7, 2001, 115 Stat. 73.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Subsec. (a). Pub. L. 107–16 struck out “the credit for State death taxes provided by section 2011 and” before “the unified credit”. 1981—Subsec. (b)(2). Pub. L. 97–34 substituted “the amount of such value, reduced as provided in paragraph (1)” for “an amount which bears the same ratio to such value (reduced as provided in paragraph (1) of this subsection) as the aggregate amount of the marital deductions allowed under section 2056(a) bears to the aggregate amount of such marital deductions computed without regard to subsection (c) thereof”. 1976—Subsec. (a). Pub. L. 94–455, § 2001(c)(1)(B), substituted “provided by section 2011 and the unified credit provided by section 2010” for “provided by section 2011”. Subsec. (b). Pub. L. 94–455, § 1902(a)(1)(A), added heading and substituted a comma for a dash after “deduction)” in pars. (2) and (3). Subsec. (c). Pub. L. 94–455, § 1902(a)(1)(B), added heading. Subsec. (d). Pub. L. 94–455, § 1902(a)(1)(C), (D), added headings for subsec. (d) and for pars. (1) and (2). Subsec. (e). Pub. L. 94–455, § 2001(a)(3), added subsec. (e). 1970—Subsec. (b)(1). Pub. L. 91–614, § 102(d)(2)(A), substituted “the calendar quarter (or calendar year if the gift was made before January 1, 1971)” for “the year”. Subsec. (d). Pub. L. 91–614, § 102(d)(2)(B), substituted “such quarter or year” for “such year” in two places. Subsec. (d)(1). Pub. L. 91–614, § 102(d)(2)(A), substituted “the calendar quarter (or calendar year if the gift was made before January 1, 1971)” for “the year”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentPub. L. 107–16, title V, § 532(d), June 7, 2001, 115 Stat. 75, provided that: “The amendments made by this section [enacting section 2058 of this title and amending this section and sections 2011, 2013 to 2016, 2053, 2056A, 2102, 2106, 2107, 2201, 2604, 6511, and 6612 of this title] shall apply to estates of decedents dying, and generation-skipping transfers, after December 31, 2004.”
+
+Effective Date of 1981 AmendmentAmendment by Pub. L. 97–34 applicable to estates of decedents dying after Dec. 31, 1981, but inapplicable under certain conditions under will executed before date which is 30 days after Aug. 13, 1981, or under trust created by such date, see section 403(e) of Pub. L. 97–34, set out as a note under section 2056 of this title.
+
+Effective Date of 1976 AmendmentPub. L. 94–455, title XIX, § 1902(c)(1), Oct. 4, 1976, 90 Stat. 1806, as amended by Pub. L. 95–600, title VII, § 703(j)(12), Nov. 6, 1978, 92 Stat. 2942, provided that: “The amendments made by paragraphs (1) through (8), and paragraphs (12)(A), (B), and (C), of subsection (a) and by subsection (b) [amending this section and sections 2011, 2013, 2016, 2038, 2053, 2055, 2056, 2106, 2107, 2108, 2201, 6167, and 6503 of this title, repealing section 2202 of this title, and enacting provisions set out as a note under section 2201 of this title] shall apply in the case of estates of decedents dying after the date of the enactment of this Act [Oct. 4, 1976], and the amendment made by paragraph (9) of subsection (a) [amending section 2204 of this title] shall apply in the case of estates of decedents dying after December 31, 1970.” Amendment by section 2001(a)(3), (c)(1)(B) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1970 AmendmentAmendment by Pub. L. 91–614 applicable with respect to gifts made after Dec. 31, 1970, see section 102(e) of Pub. L. 91–614, set out as a note under section 2501 of this title.

legal/us/code/title-26/chapter-11/section-2013.md

@@ -0,0 +1,89 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2013"
+description: "Credit for tax on prior transfers"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2013"
+citation: "26 U.S.C. § 2013"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2013"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "d01d25df24d61c09d98c7d63fde6d3f8f0135b15f4e64fc82464bd2796b1c1ae"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "643a454e1a44cde82c27b9b2b14f2610ba3d56b2fcbc43986cf6e265a4c761af"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2013 - Credit for tax on prior transfers
+
+## Text
+
+(a) General rule The tax imposed by section 2001 shall be credited with all or a part of the amount of the Federal estate tax paid with respect to the transfer of property (including property passing as a result of the exercise or non-exercise of a power of appointment) to the decedent by or from a person (herein designated as a “transferor”) who died within 10 years before, or within 2 years after, the decedent’s death. If the transferor died within 2 years of the death of the decedent, the credit shall be the amount determined under subsections (b) and (c). If the transferor predeceased the decedent by more than 2 years, the credit shall be the following percentage of the amount so determined—
+
+(1) 80 percent, if within the third or fourth years preceding the decedent’s death;
+
+(2) 60 percent, if within the fifth or sixth years preceding the decedent’s death;
+
+(3) 40 percent, if within the seventh or eighth years preceding the decedent’s death; and
+
+(4) 20 percent, if within the ninth or tenth years preceding the decedent’s death.
+
+(b) Computation of credit Subject to the limitation prescribed in subsection (c), the credit provided by this section shall be an amount which bears the same ratio to the estate tax paid (adjusted as indicated hereinafter) with respect to the estate of the transferor as the value of the property transferred bears to the taxable estate of the transferor (determined for purposes of the estate tax) decreased by any death taxes paid with respect to such estate. For purposes of the preceding sentence, the estate tax paid shall be the Federal estate tax paid increased by any credits allowed against such estate tax under section 2012, or corresponding provisions of prior laws, on account of gift tax, and for any credits allowed against such estate tax under this section on account of prior transfers where the transferor acquired property from a person who died within 10 years before the death of the decedent.
+
+(c) Limitation on credit (1) In general The credit provided in this section shall not exceed the amount by which—
+
+(A) the estate tax imposed by section 2001 or section 2101 (after deducting the credits provided for in sections 2010, 2012, and 2014) computed without regard to this section, exceeds
+
+(B) such tax computed by excluding from the decedent’s gross estate the value of such property transferred and, if applicable, by making the adjustment hereinafter indicated.
+
+If any deduction is otherwise allowable under section 2055 or section 2106(a)(2) (relating to charitable deduction) then, for the purpose of the computation indicated in subparagraph (B), the amount of such deduction shall be reduced by that part of such deduction which the value of such property transferred bears to the decedent’s entire gross estate reduced by the deductions allowed under sections 2053 and 2054, or section 2106(a)(1) (relating to deduction for expenses, losses, etc.). For purposes of this section, the value of such property transferred shall be the value as provided for in subsection (d) of this section.
+
+(2) Two or more transferors If the credit provided in this section relates to property received from 2 or more transferors, the limitation provided in paragraph (1) of this subsection shall be computed by aggregating the value of the property so transferred to the decedent. The aggregate limitation so determined shall be apportioned in accordance with the value of the property transferred to the decedent by each transferor.
+
+(d) Valuation of property transferred The value of property transferred to the decedent shall be the value used for the purpose of determining the Federal estate tax liability of the estate of the transferor but—
+
+(1) there shall be taken into account the effect of the tax imposed by section 2001 or 2101, or any estate, succession, legacy, or inheritance tax, on the net value to the decedent of such property;
+
+(2) where such property is encumbered in any manner, or where the decedent incurs any obligation imposed by the transferor with respect to such property, such encumbrance or obligation shall be taken into account in the same manner as if the amount of a gift to the decedent of such property was being determined; and
+
+(3) if the decedent was the spouse of the transferor at the time of the transferor’s death, the net value of the property transferred to the decedent shall be reduced by the amount allowed under section 2056 (relating to marital deductions), as a deduction from the gross estate of the transferor.
+
+(e) Property defined For purposes of this section, the term “property” includes any beneficial interest in property, including a general power of appointment (as defined in section 2041).
+
+(f) Treatment of additional tax imposed under section 2032A If section 2032A applies to any property included in the gross estate of the transferor and an additional tax is imposed with respect to such property under section 2032A(c) before the date which is 2 years after the date of the decedent’s death, for purposes of this section—
+
+(1) the additional tax imposed by section 2032A(c) shall be treated as a Federal estate tax payable with respect to the estate of the transferor; and
+
+(2) the value of such property and the amount of the taxable estate of the transferor shall be determined as if section 2032A did not apply with respect to such property.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 377; Pub. L. 94–455, title XIX, § 1902(a)(2), title XX, §§ 2001(c)(1)(C), 2003(c), 2006(b)(2), Oct. 4, 1976, 90 Stat. 1804, 1850, 1862, 1888; Pub. L. 99–514, title XIV, § 1432(c)(2), Oct. 22, 1986, 100 Stat. 2730; Pub. L. 100–647, title I, § 1011A(g)(7), Nov. 10, 1988, 102 Stat. 3481; Pub. L. 105–34, title X, § 1073(b)(2), Aug. 5, 1997, 111 Stat. 948; Pub. L. 107–16, title V, § 532(c)(2), June 7, 2001, 115 Stat. 74.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Subsec. (c)(1)(A). Pub. L. 107–16 struck out “2011,” after “sections 2010,”. 1997—Subsec. (g). Pub. L. 105–34 struck out heading and text of subsec. (g). Prior to amendment, text read as follows: “For purposes of this section, the estate tax paid shall not include any portion of such tax attributable to section 4980A(d).” 1988—Subsec. (g). Pub. L. 100–647 added subsec. (g). 1986—Subsec. (g). Pub. L. 99–514 struck out subsec. (g) which provided for treatment of tax imposed on certain generation-skipping transfers. 1976—Subsec. (b). Pub. L. 94–455, § 2001(c)(1)(C)(i), struck out “and increased by the exemption provided for by section 2052 or section 2106(a)(3), or the corresponding provisions of prior laws, in determining the taxable estate of the transferor for purposes of the estate tax” after “death taxes paid with respect to such estate”. Subsec. (c)(1)(A). Pub. L. 94–455, § 2001(c)(1)(C)(ii), substituted “credits provided for in sections 2010, 2011, 2012, and 2014) computed” for “credits for State death taxes, gift tax, and foreign death taxes provided for in sections 2011, 2012, and 2014) computed”. Subsec. (d)(3). Pub. L. 94–455, § 1902(a)(2), struck out “, or the corresponding provision of prior law,” after “marital deductions)”. Subsec. (f). Pub. L. 94–455, § 2003(c), added subsec. (f). Subsec. (g). Pub. L. 94–455, § 2006(b)(2), added subsec. (g).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 applicable to estates of decedents dying after Dec. 31, 1996, see section 1073(c) of Pub. L. 105–34, set out as an Effective Date of Repeal note under section 4980A of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective Date of 1986 AmendmentAmendment by Pub. L. 99–514 applicable to generation-skipping transfers (within the meaning of section 2611 of this title) made after Oct. 22, 1986, except as otherwise provided, see section 1433 of Pub. L. 99–514, set out as an Effective Date note under section 2601 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(2) of Pub. L. 94–455 applicable to estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title.

legal/us/code/title-26/chapter-11/section-2014.md

@@ -0,0 +1,109 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2014"
+description: "Credit for foreign death taxes"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2014"
+citation: "26 U.S.C. § 2014"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2014"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "5bda199d887667613ba7a6111e5166c2f5a705671e8aab71f3714f7e9660ffdb"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e50b94043a3897002c5f26d7b1a6ef779eb42ef233e120b23790afcbd0c99e07"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2014 - Credit for foreign death taxes
+
+## Text
+
+(a) In general The tax imposed by section 2001 shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any foreign country in respect of any property situated within such foreign country and included in the gross estate (not including any such taxes paid with respect to the estate of a person other than the decedent). The determination of the country within which property is situated shall be made in accordance with the rules applicable under subchapter B (sec. 2101 and following) in determining whether property is situated within or without the United States.
+
+(b) Limitations on credit The credit provided in this section with respect to such taxes paid to any foreign country—
+
+(1) shall not, with respect to any such tax, exceed an amount which bears the same ratio to the amount of such tax actually paid to such foreign country as the value of property which is—
+
+(A) situated within such foreign country,
+
+(B) subjected to such tax, and
+
+(C) included in the gross estate
+
+bears to the value of all property subjected to such tax; and
+
+(2) shall not, with respect to all such taxes, exceed an amount which bears the same ratio to the tax imposed by section 2001 (after deducting from such tax the credits provided by sections 2010 and 2012) as the value of property which is—
+
+(A) situated within such foreign country,
+
+(B) subjected to the taxes of such foreign country, and
+
+(C) included in the gross estate
+
+bears to the value of the entire gross estate reduced by the aggregate amount of the deductions allowed under sections 2055 and 2056.
+
+(c) Valuation of property (1) The values referred to in the ratio stated in subsection (b)(1) are the values determined for purposes of the tax imposed by such foreign country.
+
+(2) The values referred to in the ratio stated in subsection (b)(2) are the values determined under this chapter; but, in applying such ratio, the value of any property described in subparagraphs (A), (B), and (C) thereof shall be reduced by such amount as will properly reflect, in accordance with regulations prescribed by the Secretary, the deductions allowed in respect of such property under sections 2055 and 2056 (relating to charitable and marital deductions).
+
+(d) Proof of credit The credit provided in this section shall be allowed only if the taxpayer establishes to the satisfaction of the Secretary—
+
+(1) the amount of taxes actually paid to the foreign country,
+
+(2) the amount and date of each payment thereof,
+
+(3) the description and value of the property in respect of which such taxes are imposed, and
+
+(4) all other information necessary for the verification and computation of the credit.
+
+(e) Period of limitation The credit provided in this section shall be allowed only for such taxes as were actually paid and credit therefor claimed within 4 years after the filing of the return required by section 6018, except that—
+
+(1) If a petition for redetermination of a deficiency has been filed with the Tax Court within the time prescribed in section 6213(a), then within such 4-year period or before the expiration of 60 days after the decision of the Tax Court becomes final.
+
+(2) If, under section 6161, an extension of time has been granted for payment of the tax shown on the return, or of a deficiency, then within such 4-year period or before the date of the expiration of the period of the extension.
+
+Refund based on such credit may (despite the provisions of sections 6511 and 6512) be made if claim therefor is filed within the period above provided. Any such refund shall be made without interest.
+
+(f) Additional limitation in cases involving a deduction under section 2053(d) In any case where a deduction is allowed under section 2053(d) for an estate, succession, legacy, or inheritance tax imposed by and actually paid to any foreign country upon a transfer by the decedent for public, charitable, or religious uses described in section 2055, the property described in subparagraphs (A), (B), and (C) of paragraphs (1) and (2) of subsection (b) of this section shall not include any property in respect of which such deduction is allowed under section 2053(d).
+
+(g) Possession of United States deemed a foreign country For purposes of the credits authorized by this section, each possession of the United States shall be deemed to be a foreign country.
+
+(h) Similar credit required for certain alien residents Whenever the President finds that—
+
+(1) a foreign country, in imposing estate, inheritance, legacy, or succession taxes, does not allow to citizens of the United States resident in such foreign country at the time of death a credit similar to the credit allowed under subsection (a),
+
+(2) such foreign country, when requested by the United States to do so has not acted to provide such a similar credit in the case of citizens of the United States resident in such foreign country at the time of death, and
+
+(3) it is in the public interest to allow the credit under subsection (a) in the case of citizens or subjects of such foreign country only if it allows such a similar credit in the case of citizens of the United States resident in such foreign country at the time of death,
+
+the President shall proclaim that, in the case of citizens or subjects of such foreign country dying while the proclamation remains in effect, the credit under subsection (a) shall be allowed only if such foreign country allows such a similar credit in the case of citizens of the United States resident in such foreign country at the time of death.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 378; Pub. L. 85–866, title I, § 102(c)(2), Sept. 2, 1958, 72 Stat. 1674; Pub. L. 86–175, § 2, Aug. 21, 1959, 73 Stat. 397; Pub. L. 89–809, title I, § 106(b)(3), Nov. 13, 1966, 80 Stat. 1570; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), title XX, § 2001(c)(1)(G), Oct. 4, 1976, 90 Stat. 1834, 1852; Pub. L. 107–16, title V, § 532(c)(3), June 7, 2001, 115 Stat. 74.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Subsec. (b)(2). Pub. L. 107–16 struck out “, 2011,” after “sections 2010” in introductory provisions. 1976—Subsec. (b)(2). Pub. L. 94–455, § 2001(c)(1)(G), inserted reference to section 2010 in introductory provisions. Subsecs. (c), (d). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”. 1966—Subsec. (a). Pub. L. 89–809 struck out provision that, if the decedent at the time of his death was not a citizen of the United States, credit would not be allowed under this section unless the foreign country of which the decedent was a citizen or subject, in imposing estate, inheritance, legacy, or succession taxes, allows a similar credit in the case of a citizen of the United States resident in such country. Subsec. (h). Pub. L. 89–809 added subsec. (h). 1959—Subsecs. (f), (g). Pub. L. 86–175 added subsec. (f) and redesignated former subsec. (f) as (g). 1958—Subsec. (f). Pub. L. 85–866 added subsec. (f).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 106(b)(4) of Pub. L. 89–809, set out as a note under section 901 of this title.
+
+Effective Date of 1959 AmendmentAmendment by Pub. L. 86–175 applicable with respect to estates of decedents dying on or after July 1, 1955, see section 4 of Pub. L. 86–175, set out as a note under section 2053 of this title.
+
+Effective Date of 1958 AmendmentPub. L. 85–866, title I, § 102(d), Sept. 2, 1958, 72 Stat. 1675, provided that: “The amendments made by this section (other than by subsection (b)) [enacting section 2208 of this title and amending this section and sections 2011 and 2053 of this title] shall apply to the estates of decedents dying after the date of the enactment of this Act [Sept. 2, 1958]. The amendment made by subsection (b) [amending section 2501 of this title] shall apply to gifts made after the date of the enactment of this Act.”

legal/us/code/title-26/chapter-11/section-2015.md

@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2015"
+description: "Credit for death taxes on remainders"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2015"
+citation: "26 U.S.C. § 2015"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2015"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "0a1a3f229c1829621bd4984b53f7ac3672715507b5b529bd4cc3049a7b2b627b"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "eb06467389fe78dbdaf37d21c68c7025370d3b6d1d314314a5e229910edbf1f6"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2015 - Credit for death taxes on remainders
+
+## Text
+
+Where an election is made under section 6163(a) to postpone payment of the tax imposed by section 2001, or 2101, such part of any estate, inheritance, legacy, or succession taxes allowable as a credit under section 2014, as is attributable to a reversionary or remainder interest may be allowed as a credit against the tax attributable to such interest, subject to the limitations on the amount of the credit contained in such sections, if such part is paid, and credit therefor claimed, at any time before the expiration of the time for payment of the tax imposed by section 2001 or 2101 as postponed and extended under section 6163.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 379; Pub. L. 85–866, title I, § 66(a)(1), Sept. 2, 1958, 72 Stat. 1657; Pub. L. 107–16, title V, § 532(c)(4), June 7, 2001, 115 Stat. 74.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Pub. L. 107–16 struck out “2011 or” before “2014”. 1958—Pub. L. 85–866 substituted “the time for payment of the tax imposed by section 2001 or 2101 as postponed and extended under section 6163” for “60 days after the termination of the precedent interest or interests in the property”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1958 AmendmentPub. L. 85–866, title I, § 66(a)(3), Sept. 2, 1958, 72 Stat. 1658, provided that: “The amendments made by paragraphs (1) and (2) [amending this section and section 927 of I.R.C. 1939] shall apply in the case of any reversionary or remainder interest in property only if the precedent interest or interests in the property did not terminate before the beginning of the 60-day period which ends on the date of the enactment of this Act [Sept. 2, 1958].”

legal/us/code/title-26/chapter-11/section-2016.md

@@ -0,0 +1,49 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2016"
+description: "Recovery of taxes claimed as credit"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2016"
+citation: "26 U.S.C. § 2016"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2016"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "9dac1f860e56bb3887119dc588cd10a1f5bf66da163935bdcac490a805bca2c3"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "419e8ea0f3990c8b0ffb322088c63d3c0cd66e3f1eb0d563f0984710b66e6b27"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2016 - Recovery of taxes claimed as credit
+
+## Text
+
+If any tax claimed as a credit under section 2014 is recovered from any foreign country, the executor, or any other person or persons recovering such amount, shall give notice of such recovery to the Secretary at such time and in such manner as may be required by regulations prescribed by him, and the Secretary shall (despite the provisions of section 6501) redetermine the amount of the tax under this chapter and the amount, if any, of the tax due on such redetermination, shall be paid by the executor or such person or persons, as the case may be, on notice and demand. No interest shall be assessed or collected on any amount of tax due on any redetermination by the Secretary resulting from a refund to the executor of tax claimed as a credit under section 2014, for any period before the receipt of such refund, except to the extent interest was paid by the foreign country on such refund.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 380; Pub. L. 94–455, title XIX, §§ 1902(a)(12)(C), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1806, 1834; Pub. L. 107–16, title V, § 532(c)(4), June 7, 2001, 115 Stat. 74; Pub. L. 107–147, title IV, § 411(h), Mar. 9, 2002, 116 Stat. 46.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2002—Pub. L. 107–147 struck out “any State, any possession of the United States, or the District of Columbia,” after “any foreign country,”. 2001—Pub. L. 107–16 struck out “2011 or” before “2014 is recovered”. 1976—Pub. L. 94–455 struck out “Territory or” after “any State, any” and “or his delegate” after “Secretary”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2002 AmendmentAmendment by Pub. L. 107–147 effective as if included in the provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107–16, to which such amendment relates, see section 411(x) of Pub. L. 107–147, set out as a note under section 25B of this title.
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(12)(C) of Pub. L. 94–455 applicable to estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title.

legal/us/code/title-26/chapter-11/section-2031.md

@@ -0,0 +1,131 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2031"
+description: "Definition of gross estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2031"
+citation: "26 U.S.C. § 2031"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2031"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "5510a47fea1cf2efff957454d57934ae1e879b4fea2996d765bb4aeae4711ad6"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "21c4e81077e0f5e04610c08ff384873f2a68bebd69da7e5a1689c7980ee06249"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2031 - Definition of gross estate
+
+## Text
+
+(a) General The value of the gross estate of the decedent shall be determined by including to the extent provided for in this part, the value at the time of his death of all property, real or personal, tangible or intangible, wherever situated.
+
+(b) Valuation of unlisted stock and securities In the case of stock and securities of a corporation the value of which, by reason of their not being listed on an exchange and by reason of the absence of sales thereof, cannot be determined with reference to bid and asked prices or with reference to sales prices, the value thereof shall be determined by taking into consideration, in addition to all other factors, the value of stock or securities of corporations engaged in the same or a similar line of business which are listed on an exchange.
+
+(c) Estate tax with respect to land subject to a qualified conservation easement (1) In general If the executor makes the election described in paragraph (6), then, except as otherwise provided in this subsection, there shall be excluded from the gross estate the lesser of—
+
+(A) the applicable percentage of the value of land subject to a qualified conservation easement, reduced by the amount of any deduction under section 2055(f) with respect to such land, or
+
+(B) $500,000.
+
+(2) Applicable percentage For purposes of paragraph (1), the term “applicable percentage” means 40 percent reduced (but not below zero) by 2 percentage points for each percentage point (or fraction thereof) by which the value of the qualified conservation easement is less than 30 percent of the value of the land (determined without regard to the value of such easement and reduced by the value of any retained development right (as defined in paragraph (5))). The values taken into account under the preceding sentence shall be such values as of the date of the contribution referred to in paragraph (8)(B).
+
+[(3) Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(96), Dec. 19, 2014, 128 Stat. 4051]
+
+(4) Treatment of certain indebtedness (A) In general The exclusion provided in paragraph (1) shall not apply to the extent that the land is debt-financed property.
+
+(B) Definitions For purposes of this paragraph—
+
+(i) Debt-financed property The term “debt-financed property” means any property with respect to which there is an acquisition indebtedness (as defined in clause (ii)) on the date of the decedent’s death.
+
+(ii) Acquisition indebtedness The term “acquisition indebtedness” means, with respect to debt-financed property, the unpaid amount of—
+
+(I) the indebtedness incurred by the donor in acquiring such property,
+
+(II) the indebtedness incurred before the acquisition of such property if such indebtedness would not have been incurred but for such acquisition,
+
+(III) the indebtedness incurred after the acquisition of such property if such indebtedness would not have been incurred but for such acquisition and the incurrence of such indebtedness was reasonably foreseeable at the time of such acquisition, and
+
+(IV) the extension, renewal, or refinancing of an acquisition indebtedness.
+
+(5) Treatment of retained development right (A) In general Paragraph (1) shall not apply to the value of any development right retained by the donor in the conveyance of a qualified conservation easement.
+
+(B) Termination of retained development right If every person in being who has an interest (whether or not in possession) in the land executes an agreement to extinguish permanently some or all of any development rights (as defined in subparagraph (D)) retained by the donor on or before the date for filing the return of the tax imposed by section 2001, then any tax imposed by section 2001 shall be reduced accordingly. Such agreement shall be filed with the return of the tax imposed by section 2001. The agreement shall be in such form as the Secretary shall prescribe.
+
+(C) Additional tax Any failure to implement the agreement described in subparagraph (B) not later than the earlier of—
+
+(i) the date which is 2 years after the date of the decedent’s death, or
+
+(ii) the date of the sale of such land subject to the qualified conservation easement,
+
+shall result in the imposition of an additional tax in the amount of the tax which would have been due on the retained development rights subject to such agreement. Such additional tax shall be due and payable on the last day of the 6th month following such date.
+
+(D) Development right defined For purposes of this paragraph, the term “development right” means any right to use the land subject to the qualified conservation easement in which such right is retained for any commercial purpose which is not subordinate to and directly supportive of the use of such land as a farm for farming purposes (within the meaning of section 2032A(e)(5)).
+
+(6) Election The election under this subsection shall be made on or before the due date (including extensions) for filing the return of tax imposed by section 2001 and shall be made on such return. Such an election, once made, shall be irrevocable.
+
+(7) Calculation of estate tax due An executor making the election described in paragraph (6) shall, for purposes of calculating the amount of tax imposed by section 2001, include the value of any development right (as defined in paragraph (5)) retained by the donor in the conveyance of such qualified conservation easement. The computation of tax on any retained development right prescribed in this paragraph shall be done in such manner and on such forms as the Secretary shall prescribe.
+
+(8) Definitions For purposes of this subsection—
+
+(A) Land subject to a qualified conservation easement The term “land subject to a qualified conservation easement” means land—
+
+(i) which is located in the United States or any possession of the United States,
+
+(ii) which was owned by the decedent or a member of the decedent’s family at all times during the 3-year period ending on the date of the decedent’s death, and
+
+(iii) with respect to which a qualified conservation easement has been made by an individual described in subparagraph (C), as of the date of the election described in paragraph (6).
+
+(B) Qualified conservation easement The term “qualified conservation easement” means a qualified conservation contribution (as defined in section 170(h)(1)) of a qualified real property interest (as defined in section 170(h)(2)(C)), except that clause (iv) of section 170(h)(4)(A) shall not apply, and the restriction on the use of such interest described in section 170(h)(2)(C) shall include a prohibition on more than a de minimis use for a commercial recreational activity.
+
+(C) Individual described An individual is described in this subparagraph if such individual is—
+
+(i) the decedent,
+
+(ii) a member of the decedent’s family,
+
+(iii) the executor of the decedent’s estate, or
+
+(iv) the trustee of a trust the corpus of which includes the land to be subject to the qualified conservation easement.
+
+(D) Member of family The term “member of the decedent’s family” means any member of the family (as defined in section 2032A(e)(2)) of the decedent.
+
+(9) Treatment of easements granted after death In any case in which the qualified conservation easement is granted after the date of the decedent’s death and on or before the due date (including extensions) for filing the return of tax imposed by section 2001, the deduction under section 2055(f) with respect to such easement shall be allowed to the estate but only if no charitable deduction is allowed under chapter 1 to any person with respect to the grant of such easement.
+
+(10) Application of this section to interests in partnerships, corporations, and trusts This section shall apply to an interest in a partnership, corporation, or trust if at least 30 percent of the entity is owned (directly or indirectly) by the decedent, as determined under the rules described in section 2057(e)(3) (as in effect before its repeal).
+
+(d) Cross reference For executor’s right to be furnished on request a statement regarding any valuation made by the Secretary within the gross estate, see section 7517.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 380; Pub. L. 87–834, § 18(a)(1), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XX, § 2008(a)(2)(A), Oct. 4, 1976, 90 Stat. 1891; Pub. L. 105–34, title V, § 508(a), Aug. 5, 1997, 111 Stat. 857; Pub. L. 105–206, title VI, § 6007(g), July 22, 1998, 112 Stat. 810; Pub. L. 105–277, div. J, title IV, § 4006(c)(3), Oct. 21, 1998, 112 Stat. 2681–913; Pub. L. 107–16, title V, § 551(a), (b), June 7, 2001, 115 Stat. 86; Pub. L. 113–295, div. A, title II, § 221(a)(96), (97)(B), Dec. 19, 2014, 128 Stat. 4051; Pub. L. 115–141, div. U, title IV, § 401(a)(200), (201), Mar. 23, 2018, 132 Stat. 1193.)
+
+## Notes
+
+Editorial Notes
+
+References in TextSection 2057, referred to in subsec. (c)(10), was repealed by Pub. L. 113–295, div. A, title II, § 221(a)(97)(A), Dec. 19, 2014, 128 Stat. 4051, effective Dec. 19, 2014.
+
+Amendments2018—Subsec. (c)(1)(B). Pub. L. 115–141, § 401(a)(200), substituted “(B) $500,000.” for “(II) $500,000.” Subsec. (c)(2). Pub. L. 115–141, § 401(a)(201), substituted “paragraph (5))).” for “paragraph (5)).” 2014—Subsec. (c)(1). Pub. L. 113–295, § 221(a)(96), substituted “(II) $500,000.” for “(B) the exclusion limitation.” Subsec. (c)(3). Pub. L. 113–295, § 221(a)(96), struck out par. (3), which set out table of exclusion limitations. Subsec. (c)(10). Pub. L. 113–295, § 221(a)(97)(B), inserted “(as in effect before its repeal)” before period at end. 2001—Subsec. (c)(2). Pub. L. 107–16, § 551(b), inserted at end “The values taken into account under the preceding sentence shall be such values as of the date of the contribution referred to in paragraph (8)(B).” Subsec. (c)(8)(A)(i). Pub. L. 107–16, § 551(a), amended cl. (i) generally. Prior to amendment, cl. (i) read as follows: “which is located— “(I) in or within 25 miles of an area which, on the date of the decedent’s death, is a metropolitan area (as defined by the Office of Management and Budget), “(II) in or within 25 miles of an area which, on the date of the decedent’s death, is a national park or wilderness area designated as part of the National Wilderness Preservation System (unless it is determined by the Secretary that land in or within 25 miles of such a park or wilderness area is not under significant development pressure), or “(III) in or within 10 miles of an area which, on the date of the decedent’s death, is an Urban National Forest (as designated by the Forest Service),”. 1998—Subsec. (c)(6). Pub. L. 105–206, § 6007(g)(2), substituted “on or before the due date (including extensions) for filing the return of tax imposed by section 2001 and shall be made on such return.” for “on the return of the tax imposed by section 2001.” Subsec. (c)(9). Pub. L. 105–206, § 6007(g)(1), added par. (9). Former par. (9) redesignated (10). Subsec. (c)(10). Pub. L. 105–277, § 4006(c)(3), substituted “section 2057(e)(3)” for “section 2033A(e)(3)”. Pub. L. 105–206, § 6007(g)(1), redesignated par. (9) as (10). 1997—Subsecs. (c), (d). Pub. L. 105–34 added subsec. (c) and redesignated former subsec. (c) as (d). 1976—Subsec. (c). Pub. L. 94–455 added subsec. (c). 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2014 AmendmentAmendment by Pub. L. 113–295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as a note under section 1 of this title.
+
+Effective Date of 2001 AmendmentPub. L. 107–16, title V, § 551(c), June 7, 2001, 115 Stat. 86, provided that: “The amendments made by this section [amending this section] shall apply to estates of decedents dying after December 31, 2000.”
+
+Effective Date of 1998 AmendmentAmendment by Pub. L. 105–206 effective, except as otherwise provided, as if included in the provisions of the Taxpayer Relief Act of 1997, Pub. L. 105–34, to which such amendment relates, see section 6024 of Pub. L. 105–206, set out as a note under section 1 of this title.
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 applicable to estates of decedents dying after Dec. 31, 1997, see section 508(e)(1) of Pub. L. 105–34, set out as a note under section 1014 of this title.
+
+Effective Date of 1962 AmendmentPub. L. 87–834, § 18(b), Oct. 16, 1962, 76 Stat. 1052, provided that: “(1) Except as provided in paragraph (2), the amendments made by subsection (a) [amending this section and sections 2033, 2034, 2035, 2036, 2037, 2038, 2040, and 2041 of this title] shall apply to the estates of decedents dying after the date of the enactment of this Act [Oct. 16, 1962]. “(2) In the case of a decedent dying after the date of the enactment of this Act [Oct. 16, 1962] and before July 1, 1964, the value of real property situated outside of the United States shall not be included in the gross estate (as defined in section 2031(a)) of the decedent—“(A) under section 2033, 2034, 2035(a), 2036(a), 2037(a), or 2038(a) to the extent the real property, or the decedent’s interest in it, was acquired by the decedent before February 1, 1962; “(B) under section 2040 to the extent such property or interest was acquired by the decedent before February 1, 1962, or was held by the decedent and the survivor in a joint tenancy or tenancy by the entirety before February 1, 1962; or “(C) under section 2041(a) to the extent that before February 1, 1962, such property or interest was subject to a general power of appointment (as defined in section 2041) possessed by the decedent. In the case of real property, or an interest therein, situated outside of the United States (including a general power of appointment in respect of such property or interest, and including property held by the decedent and the survivor in a joint tenancy or tenancy by the entirety) which was acquired by the decedent after January 31, 1962, by gift within the meaning of section 2511, or from a prior decedent by devise or inheritance, or by reason of death, form of ownership, or other conditions (including the exercise or nonexercise of a power of appointment), for purposes of this paragraph such property or interest therein shall be deemed to have been acquired by the decedent before February 1, 1962, if before that date the donor or prior decedent had acquired the property or his interest therein or had possessed a power of appointment in respect of the property or interest.”

legal/us/code/title-26/chapter-11/section-2032.md

@@ -0,0 +1,73 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2032"
+description: "Alternate valuation"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2032"
+citation: "26 U.S.C. § 2032"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2032"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "65b7ae1cf4e23493d8554cbad4ae9a0bbf185bf14345d27d9fcdc7d23fbcc2cb"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e0654936baf1c2df20ce7a6915bd5a64849fd856733fd45e29ce4f3c850e8fb5"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2032 - Alternate valuation
+
+## Text
+
+(a) General The value of the gross estate may be determined, if the executor so elects, by valuing all the property included in the gross estate as follows:
+
+(1) In the case of property distributed, sold, exchanged, or otherwise disposed of, within 6 months after the decedent’s death such property shall be valued as of the date of distribution, sale, exchange, or other disposition.
+
+(2) In the case of property not distributed, sold, exchanged, or otherwise disposed of, within 6 months after the decedent’s death such property shall be valued as of the date 6 months after the decedent’s death.
+
+(3) Any interest or estate which is affected by mere lapse of time shall be included at its value as of the time of death (instead of the later date) with adjustment for any difference in its value as of the later date not due to mere lapse of time.
+
+(b) Special rules No deduction under this chapter of any item shall be allowed if allowance for such items is in effect given by the alternate valuation provided by this section. Wherever in any other subsection or section of this chapter reference is made to the value of property at the time of the decedent’s death, such reference shall be deemed to refer to the value of such property used in determining the value of the gross estate. In case of an election made by the executor under this section, then—
+
+(1) for purposes of the charitable deduction under section 2055 or 2106(a)(2), any bequest, legacy, devise, or transfer enumerated therein, and
+
+(2) for the purpose of the marital deduction under section 2056, any interest in property passing to the surviving spouse,
+
+shall be valued as of the date of the decedent’s death with adjustment for any difference in value (not due to mere lapse of time or the occurrence or nonoccurrence of a contingency) of the property as of the date 6 months after the decedent’s death (substituting, in the case of property distributed by the executor or trustee, or sold, exchanged, or otherwise disposed of, during such 6-month period, the date thereof).
+
+(c) Election must decrease gross estate and estate tax No election may be made under this section with respect to an estate unless such election will decrease—
+
+(1) the value of the gross estate, and
+
+(2) the sum of the tax imposed by this chapter and the tax imposed by chapter 13 with respect to property includible in the decedent’s gross estate (reduced by credits allowable against such taxes).
+
+(d) Election (1) In general The election provided for in this section shall be made by the executor on the return of the tax imposed by this chapter. Such election, once made, shall be irrevocable.
+
+(2) Exception No election may be made under this section if such return is filed more than 1 year after the time prescribed by law (including extensions) for filing such return.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 381; Pub. L. 91–614, title I, § 101(a), Dec. 31, 1970, 84 Stat. 1836; Pub. L. 98–369, div. A, title X, §§ 1023(a), 1024(a), July 18, 1984, 98 Stat. 1030; Pub. L. 99–514, title XIV, § 1432(c)(1), Oct. 22, 1986, 100 Stat. 2730.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1986—Subsec. (c)(2). Pub. L. 99–514 amended par. (2) generally. Prior to amendment, par. (2) read as follows: “the amount of the tax imposed by this chapter (reduced by credits allowable against such tax).” 1984—Subsec. (c). Pub. L. 98–369, § 1023(a), added subsec. (c). Former subsec. (c) redesignated (d). Subsec. (d). Pub. L. 98–369, § 1024(a), substituted “Election” for “Time of election” in heading, designated existing text as par. (1), inserted heading “In general”, substituted “shall be made by the executor on the return of the tax imposed by this chapter” for “shall be exercised by the executor on his return if filed within the time prescribed by law or before the expiration of any extension of time granted pursuant to law for the filing of the return”, inserted sentence providing that an election, once made, is irrevocable, and added par. (2). Pub. L. 98–369, § 1023(a), redesignated subsec. (c) as (d). 1970—Pub. L. 91–614 substituted “6 months” for “1 year” in four places and substituted “6-month” for “1-year”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1986 AmendmentAmendment by Pub. L. 99–514 applicable to generation-skipping transfers (within the meaning of section 2611 of this title) made after Oct. 22, 1986, except as otherwise provided, see section 1433 of Pub. L. 99–514, set out as an Effective Date note under section 2601 of this title.
+
+Effective Date of 1984 AmendmentPub. L. 98–369, div. A, title X, § 1023(b), July 18, 1984, 98 Stat. 1030, provided that: “The amendments made by subsection (a) [amending this section] shall apply with respect to estates of decedents dying after the date of the enactment of this Act [July 18, 1984].” Pub. L. 98–369, div. A, title X, § 1024(b), July 18, 1984, 98 Stat. 1030, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “(1) In general.—The amendment made by subsection (a) [amending this section] shall apply to estates of decedents dying after the date of the enactment of this Act [July 18, 1984]. “(2) Transitional rule.—In the case of an estate of a decedent dying before the date of the enactment of this Act [July 18, 1984] if—“(A) a credit or refund of the tax imposed by chapter 11 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] is not prevented on the date of the enactment of this Act by the operation of any law or rule of law, “(B) the election under section 2032 of the Internal Revenue Code of 1986 would have met the requirements of such section (as amended by this section and section 1023) had the decedent died after the date of enactment of this Act, and “(C) a claim for credit or refund of such tax with respect to such estate is filed not later than the 90th day after the date of the enactment of this Act, then such election shall be treated as a valid election under such section 2032. The statutory period for the assessment of any deficiency which is attributable to an election under this paragraph shall not expire before the close of the 2-year period beginning on the date of the enactment of this Act.”
+
+Effective Date of 1970 AmendmentPub. L. 91–614, title I, § 101(j), Dec. 31, 1970, 84 Stat. 1838, provided that: “The amendments made by this section [enacting section 6905 of this title, amending this section and sections 1223, 2055, 2204, 6040, 6075, 6091, 6161, 6314, 6324, and 6504 of this title, and enacting provisions set out as notes under this section and sections 2204 and 6905 of this title] (other than subsection (f)) [amending sections 2204 and 6905 of this title] shall apply with respect to decedents dying after December 31, 1970.”

legal/us/code/title-26/chapter-11/section-2033.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2033"
+description: "Property in which the decedent had an interest"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2033"
+citation: "26 U.S.C. § 2033"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2033"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "358b3ed7b5038c00e912c1d50c6245f59fc8d1ade54f46e7a4f07c2705ced5ec"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "fb52983211de048bb94a1d5c8582ef5106573418e9fb818ed09767e0f158b78b"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2033 - Property in which the decedent had an interest
+
+## Text
+
+The value of the gross estate shall include the value of all property to the extent of the interest therein of the decedent at the time of his death.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 381; Pub. L. 87–834, § 18(a)(2)(A), Oct. 16, 1962, 76 Stat. 1052.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1962—Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.

legal/us/code/title-26/chapter-11/section-2033a.md

@@ -0,0 +1,31 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2033A"
+description: "Renumbered § 2057]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2033A"
+citation: "26 U.S.C. § 2033A"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2033A"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "2877bd7c7664a937247ad0e88df09238efa07943e166abf39c52b6ca5a48277e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "01ba4719c80b6fe911b091a7c05124b64eeece964e09c058ef8f9805daca546b"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2033A - Renumbered § 2057]
+
+

legal/us/code/title-26/chapter-11/section-2034.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2034"
+description: "Dower or curtesy interests"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2034"
+citation: "26 U.S.C. § 2034"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2034"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "a22ac71298341aa532145fedd37b9738be03f56fa8738a4754c92c7c5dcc36d7"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "4b9b5db6cfa9ebc13576e5ec67c546dc2a78d81504afa55229d75cdbfb2ae2de"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2034 - Dower or curtesy interests
+
+## Text
+
+The value of the gross estate shall include the value of all property to the extent of any interest therein of the surviving spouse, existing at the time of the decedent’s death as dower or curtesy, or by virtue of a statute creating an estate in lieu of dower or curtesy.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 381; Pub. L. 87–834, § 18(a)(2)(B), Oct. 16, 1962, 76 Stat. 1052.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1962—Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.

legal/us/code/title-26/chapter-11/section-2035.md

@@ -0,0 +1,83 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2035"
+description: "Adjustments for certain gifts made within 3 years of decedent’s death"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2035"
+citation: "26 U.S.C. § 2035"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2035"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "ebeb351c65ad9870443b26c51da286b94eb1f0b1b41a6fd1df9211b5c087f93d"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "9aaf6a3f630547452f744837ecd9fc83742d6afeb07bd2fff4849d517e1367cf"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2035 - Adjustments for certain gifts made within 3 years of decedent’s death
+
+## Text
+
+(a) Inclusion of certain property in gross estate If—
+
+(1) the decedent made a transfer (by trust or otherwise) of an interest in any property, or relinquished a power with respect to any property, during the 3-year period ending on the date of the decedent’s death, and
+
+(2) the value of such property (or an interest therein) would have been included in the decedent’s gross estate under section 2036, 2037, 2038, or 2042 if such transferred interest or relinquished power had been retained by the decedent on the date of his death,
+
+the value of the gross estate shall include the value of any property (or interest therein) which would have been so included.
+
+(b) Inclusion of gift tax on gifts made during 3 years before decedent’s death The amount of the gross estate (determined without regard to this subsection) shall be increased by the amount of any tax paid under chapter 12 by the decedent or his estate on any gift made by the decedent or his spouse during the 3-year period ending on the date of the decedent’s death.
+
+(c) Other rules relating to transfers within 3 years of death (1) In general For purposes of—
+
+(A) section 303(b) (relating to distributions in redemption of stock to pay death taxes),
+
+(B) section 2032A (relating to special valuation of certain farms, etc., real property), and
+
+(C) subchapter C of chapter 64 (relating to lien for taxes),
+
+the value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has at any time made a transfer, by trust or otherwise, during the 3-year period ending on the date of the decedent’s death.
+
+(2) Coordination with section 6166 An estate shall be treated as meeting the 35 percent of adjusted gross estate requirement of section 6166(a)(1) only if the estate meets such requirement both with and without the application of subsection (a).
+
+(3) Marital and small transfers Paragraph (1) shall not apply to any transfer (other than a transfer with respect to a life insurance policy) made during a calendar year to any donee if the decedent was not required by section 6019 (other than by reason of section 6019(2)) to file any gift tax return for such year with respect to transfers to such donee.
+
+(d) Exception Subsection (a) and paragraph (1) of subsection (c) shall not apply to any bona fide sale for an adequate and full consideration in money or money’s worth.
+
+(e) Treatment of certain transfers from revocable trusts For purposes of this section and section 2038, any transfer from any portion of a trust during any period that such portion was treated under section 676 as owned by the decedent by reason of a power in the grantor (determined without regard to section 672(e)) shall be treated as a transfer made directly by the decedent.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 381; Pub. L. 87–834, § 18(a)(2)(C), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XX, § 2001(a)(5), Oct. 4, 1976, 90 Stat. 1848; Pub. L. 95–600, title VII, § 702(f)(1), Nov. 6, 1978, 92 Stat. 2930; Pub. L. 97–34, title IV, §§ 403(b)(3)(B), 424(a), Aug. 13, 1981, 95 Stat. 301, 317; Pub. L. 97–448, title I, § 104(a)(9), (d)(1)(A), (C), (2), Jan. 12, 1983, 96 Stat. 2381, 2383; Pub. L. 105–34, title XIII, § 1310(a), Aug. 5, 1997, 111 Stat. 1043; Pub. L. 106–554, § 1(a)(7) [title III, § 319(14)], Dec. 21, 2000, 114 Stat. 2763, 2763A–646.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2000—Subsec. (c)(2). Pub. L. 106–554, § 1(a)(7) [title III, § 319(14)(A)], substituted “subsection (a)” for “paragraph (1)”. Subsec. (d). Pub. L. 106–554, § 1(a)(7) [title III, § 319(14)(B)], inserted “and paragraph (1) of subsection (c)” after “Subsection (a)”. 1997—Pub. L. 105–34 amended section catchline and text generally. Prior to amendment, section consisted of subsecs. (a) to (d) relating to adjustments for gifts made within 3 years of decedent’s death. 1983—Subsec. (b)(2). Pub. L. 97–448, § 104(a)(9), substituted “section 6019(2)” for “section 6019(a)(2)”. Subsec. (d)(2). Pub. L. 97–448, § 104(d)(2), inserted “of this subsection and paragraph (2) of subsection (b)” after “Paragraph (1)”, and struck out “2041,” after “2038,”. Subsec. (d)(3)(C), (D). Pub. L. 97–448, § 104(d)(1)(C), redesignated subpar. (D) as (C). Former subpar. (C), which referred to section 6166 (relating to extension of time for payment of estate tax where estate consists largely of interest in closely held business), was struck out. Subsec. (d)(4). Pub. L. 97–448, § 104(d)(1)(A), added par. (4). 1981—Subsec. (b)(2). Pub. L. 97–34, § 403(b)(3)(B), inserted “(other than by reason of section 6019(a)(2))” after “section 6019”. Subsec. (d). Pub. L. 97–34, § 424(a), added subsec. (d). 1978—Subsec. (b). Pub. L. 95–600 substituted in par. (2) provisions relating to gifts for which donee was not required by section 6019 to file gift tax returns for provisions relating to gifts excludable in computing taxable gifts by reason of section 2503(b) and inserted provisions following par. (2) relating to inapplicability of par. (2) to transfers respecting life insurance policies. 1976—Pub. L. 94–455 substituted provisions covering adjustments for gifts made within 3 years of decedent’s death for provisions under which transfers by the decedent within 3 years of the decedent’s death were deemed to have been made in contemplation of death and included in the value of the gross estate. 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1997 AmendmentPub. L. 105–34, title XIII, § 1310(c), Aug. 5, 1997, 111 Stat. 1044, provided that: “The amendments made by this section [amending this section] shall apply to the estates of decedents dying after the date of the enactment of this Act [Aug. 5, 1997].”
+
+Effective Date of 1983 AmendmentAmendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.
+
+Effective Date of 1981 AmendmentAmendment by section 403(b)(3)(B) of Pub. L. 97–34 applicable to estates of decedents dying after Dec. 31, 1981, see section 403(e) of Pub. L. 97–34, set out as a note under section 2056 of this title. Pub. L. 97–34, title IV, § 424(b), Aug. 13, 1981, 95 Stat. 317, provided that: “The amendment made by subsection (a) [amending this section] shall apply to the estates of decedents dying after December 31, 1981.”
+
+Effective Date of 1978 AmendmentPub. L. 95–600, title VII, § 702(f)(2), Nov. 6, 1978, 92 Stat. 2930, provided that: “The amendment made by paragraph (1) [amending this section] shall apply to the estates of decedents dying after December 31, 1976, except that it shall not apply to transfers made before January 1, 1977.”
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, but not to transfers made before Jan. 1, 1977, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.
+
+Transfers Made by Decedent During 1977; Election Available to Executor On or Before Due Date for Filing Estate Tax ReturnPub. L. 96–222, title I, § 107(a)(2)(F), Apr. 1, 1980, 94 Stat. 223, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “(i) If the executor elects the benefits of this subparagraph with respect to any estate, section 2035(b) of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] (relating to adjustments for gifts made within 3 years of decedent’s death) shall be applied with respect to transfers made by the decedent during 1977 as if paragraph (2) of such section 2035(b) read as follows:“ ‘(2) to any gift to a donee made during 1977 to the extent of the amount of such gift which was excludable in computing taxable gifts by reason of section 2503(b) (relating to $3,000 annual exclusion for purposes of the gift tax) determined without regard to section 2513(a).’ “(ii) The election under clause (i) with respect to any estate shall be made on or before the later of—“(I) the due date for filing the estate tax return, or “(II) the day which is 120 days after the date of the enactment of this Act [Apr. 1, 1980].”

legal/us/code/title-26/chapter-11/section-2036.md

@@ -0,0 +1,67 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2036"
+description: "Transfers with retained life estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2036"
+citation: "26 U.S.C. § 2036"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2036"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "bf58c39e0ab5ae08c18382d2d8fd09246426bb5542ef99c330ce11c1c1d4a06e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "d23fc075c9c6931f7c63d6418e78401073f8ac7934ff6460a16a62d706d9b1fc"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2036 - Transfers with retained life estate
+
+## Text
+
+(a) General rule The value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise, under which he has retained for his life or for any period not ascertainable without reference to his death or for any period which does not in fact end before his death—
+
+(1) the possession or enjoyment of, or the right to the income from, the property, or
+
+(2) the right, either alone or in conjunction with any person, to designate the persons who shall possess or enjoy the property or the income therefrom.
+
+(b) Voting rights (1) In general For purposes of subsection (a)(1), the retention of the right to vote (directly or indirectly) shares of stock of a controlled corporation shall be considered to be a retention of the enjoyment of transferred property.
+
+(2) Controlled corporation For purposes of paragraph (1), a corporation shall be treated as a controlled corporation if, at any time after the transfer of the property and during the 3-year period ending on the date of the decedent’s death, the decedent owned (with the application of section 318), or had the right (either alone or in conjunction with any person) to vote, stock possessing at least 20 percent of the total combined voting power of all classes of stock.
+
+(3) Coordination with section 2035 For purposes of applying section 2035 with respect to paragraph (1), the relinquishment or cessation of voting rights shall be treated as a transfer of property made by the decedent.
+
+(c) Limitation on application of general rule This section shall not apply to a transfer made before March 4, 1931; nor to a transfer made after March 3, 1931, and before June 7, 1932, unless the property transferred would have been includible in the decedent’s gross estate by reason of the amendatory language of the joint resolution of March 3, 1931 (46 Stat. 1516).
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 382; Pub. L. 87–834, § 18(a)(2)(D), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XX, § 2009(a), Oct. 4, 1976, 90 Stat. 1893; Pub. L. 95–600, title VII, § 702(i)(1), (2), Nov. 6, 1978, 92 Stat. 2931; Pub. L. 100–203, title X, § 10402(a), Dec. 22, 1987, 101 Stat. 1330–431; Pub. L. 100–647, title III, § 3031(a)(1), (b)–(e), (g), Nov. 10, 1988, 102 Stat. 3634–3638; Pub. L. 101–508, title XI, § 11601(a), Nov. 5, 1990, 104 Stat. 1388–490.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1990—Subsecs. (c), (d). Pub. L. 101–508 redesignated subsec. (d) as (c) and struck out former subsec. (c) which enunciated a rule that retention of retained interest would be considered to be a retention of enjoyment of transferred property if a person held a substantial interest in an enterprise, and such person in effect transferred after Dec. 17, 1987, property having a disproportionately large share of the potential appreciation in such person’s interest in the enterprise while retaining an interest in the income of, or rights in, the enterprise. 1988—Subsec. (c)(1)(B). Pub. L. 100–647, § 3031(e), substituted “an interest” for “a disproportionately large share” after “whole retaining”. Subsec. (c)(2). Pub. L. 100–647, § 3031(g)(1), substituted “consideration furnished by” for “sales to” in heading, and amended text generally. Prior to amendment, text read as follows: “The exception contained in subsection (a) for a bona fide sale shall not apply to a transfer described in paragraph (1) if such transfer is to a member of the transferor’s family.” Subsec. (c)(3)(C). Pub. L. 100–647, § 3031(d), substituted “Except as provided in regulations, an” for “An”. Subsec. (c)(4). Pub. L. 100–647, § 3031(a)(1), amended par. (4) generally, substituting provisions relating to treatment of certain transfers for provisions relating to coordination with section 2035. Subsec. (c)(5). Pub. L. 100–647, § 3031(g)(2), amended par. (5) generally, substituting provisions relating to the making of appropriate adjustments in amounts included in gross estate for provisions relating to coordination with section 2043. Subsec. (c)(6). Pub. L. 100–647, § 3031(b), added par. (6). Subsec. (c)(7), (8). Pub. L. 100–647, § 3031(b)[(c)], added pars. (7) and (8). 1987—Subsecs. (c), (d). Pub. L. 100–203 added subsec. (c) and redesignated former subsec. (c) as (d). 1978—Subsec. (a). Pub. L. 95–600, § 702(i)(2), struck out provision following par. (2) relating to the retention of voting rights in retained stock. Subsecs. (b), (c). Pub. L. 95–600, § 702(i)(1), added subsec. (b) and redesignated former subsec. (b) as (c). 1976—Subsec. (a). Pub. L. 94–455 provided that, for purposes of par. (1), the retention of voting rights in retained stock be considered to be a retention of the enjoyment of that stock. 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1990 AmendmentPub. L. 101–508, title XI, § 11601(c), Nov. 5, 1990, 104 Stat. 1388–491, provided that: “The amendments made by this section [amending this section and sections 2207B and 2501 of this title] shall apply in the case of property transferred after December 17, 1987.”
+
+Effective Date of 1988 AmendmentPub. L. 100–647, title III, § 3031(h), Nov. 10, 1988, 102 Stat. 3639, provided that: “(1) In general.—Except as provided in this subsection, any amendment made by this section [enacting section 2207B of this title and amending this section and section 2501 of this title] shall take effect as if included in the provisions of the Revenue Act of 1987 [Pub. L. 100–203, title X] to which such amendment relates. “(2) Subsection (a).—The amendments made by subsection (a) [amending this section and section 2501 of this title] shall apply in cases where the transfer referred to in section 2036(c)(1)(B) of the 1986 Code is on or after June 21, 1988. “(3) Subsection (f).—If an amount is included in the gross estate of a decedent under section 2036 of the 1986 Code other than solely by reason of section 2036(c) of the 1986 Code, the amendments made by subsection (f) [enacting section 2207B of this title] shall apply to such amount only with respect to property transferred after the date of the enactment of this Act [Nov. 10, 1988]. “(4) Correction period.—If section 2036(c)(1) of the 1986 Code would (but for this paragraph) apply to any interest arising from a transaction entered into during the period beginning after December 17, 1987, and ending before January 1, 1990, such section shall not apply to such interest if—“(A) during such period, such actions are taken as are necessary to have such section 2036(c)(1) not apply to such transaction (and any such interest), or “(B) the original transferor and his spouse on January 1, 1990 (or, if earlier, the date of the original transferor’s death), does not hold any interest in the enterprise involved. “(5) Clarification of effective date.—For purposes of section 10402(b) of the Revenue Act of 1987 [Pub. L. 100–203, set out as an Effective Date of 1987 Amendment note below], with respect to property transferred on or before December 17, 1987—“(A) any failure to exercise a right of conversion, “(B) any failure to pay dividends, and“(c) [sic] failures to exercise other rights specified in regulations, shall not be treated as a subsequent transfer.”
+
+Effective Date of 1987 AmendmentPub. L. 100–203, title X, § 10402(b), Dec. 22, 1987, 101 Stat. 1330–432, provided that: “The amendment made by subsection (a) [amending this section] shall apply with respect to estates of decedents dying after December 31, 1987, but only in the case of property transferred after December 17, 1987.” [For clarification of this note, see section 3031(h)(5) of Pub. L. 100–647, set out as an Effective Date of 1988 Amendment note above.]
+
+Effective Date of 1978 AmendmentPub. L. 95–600, title VII, § 702(i)(3), Nov. 6, 1978, 92 Stat. 2931, provided that: “The amendments made by this subsection [amending this section] shall apply to transfers made after June 22, 1976.”
+
+Effective Date of 1976 AmendmentPub. L. 94–455, title XX, § 2009(e)(1), Oct. 4, 1976, 90 Stat. 1896, provided that: “The amendment made by subsection (a) [amending this section] shall apply to transfers made after June 22, 1976.”
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.

legal/us/code/title-26/chapter-11/section-2037.md

@@ -0,0 +1,57 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2037"
+description: "Transfers taking effect at death"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2037"
+citation: "26 U.S.C. § 2037"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2037"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "13c6b2c976c0e660391ed1c66e7335367947bbac5dd582bb9285889bc00f7b97"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "9088e67ddc9314c7c66d45e49587351a9601d9de0743e01006eaaca466284b8e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2037 - Transfers taking effect at death
+
+## Text
+
+(a) General rule The value of the gross estate shall include the value of all property to the extent of any interest therein of which the decedent has at any time after September 7, 1916, made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise, if—
+
+(1) possession or enjoyment of the property can, through ownership of such interest, be obtained only by surviving the decedent, and
+
+(2) the decedent has retained a reversionary interest in the property (but in the case of a transfer made before October 8, 1949, only if such reversionary interest arose by the express terms of the instrument of transfer), and the value of such reversionary interest immediately before the death of the decedent exceeds 5 percent of the value of such property.
+
+(b) Special rules For purposes of this section, the term “reversionary interest” includes a possibility that property transferred by the decedent—
+
+(1) may return to him or his estate, or
+
+(2) may be subject to a power of disposition by him,
+
+but such term does not include a possibility that the income alone from such property may return to him or become subject to a power of disposition by him. The value of a reversionary interest immediately before the death of the decedent shall be determined (without regard to the fact of the decedent’s death) by usual methods of valuation, including the use of tables of mortality and actuarial principles, under regulations prescribed by the Secretary. In determining the value of a possibility that property may be subject to a power of disposition by the decedent, such possibility shall be valued as if it were a possibility that such property may return to the decedent or his estate. Notwithstanding the foregoing, an interest so transferred shall not be included in the decedent’s gross estate under this section if possession or enjoyment of the property could have been obtained by any beneficiary during the decedent’s life through the exercise of a general power of appointment (as defined in section 2041) which in fact was exercisable immediately before the decedent’s death.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 382; Pub. L. 87–834, § 18(a)(2)(E), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XIX, § 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Subsec. (b). Pub. L. 94–455 struck out “or his delegate” after “Secretary”. 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.

legal/us/code/title-26/chapter-11/section-2038.md

@@ -0,0 +1,55 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2038"
+description: "Revocable transfers"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2038"
+citation: "26 U.S.C. § 2038"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2038"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "072157f7e4cfd1e3b16634e2ea07b06a95cb82ab83c8016975834891fd802478"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "79f1e30bb619ed749b7060966bd0bc89b45eac39d75b56bfdd59c137efc95f32"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2038 - Revocable transfers
+
+## Text
+
+(a) In general The value of the gross estate shall include the value of all property—
+
+(1) Transfers after June 22, 1936 To the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power (in whatever capacity exercisable) by the decedent alone or by the decedent in conjunction with any other person (without regard to when or from what source the decedent acquired such power), to alter, amend, revoke, or terminate, or where any such power is relinquished during the 3 year period ending on the date of the decedent’s death.
+
+(2) Transfers on or before June 22, 1936 To the extent of any interest therein of which the decedent has at any time made a transfer (except in case of a bona fide sale for an adequate and full consideration in money or money’s worth), by trust or otherwise, where the enjoyment thereof was subject at the date of his death to any change through the exercise of a power, either by the decedent alone or in conjunction with any person, to alter, amend, or revoke, or where the decedent relinquished any such power during the 3 year period ending on the date of the decedent’s death. Except in the case of transfers made after June 22, 1936, no interest of the decedent of which he has made a transfer shall be included in the gross estate under paragraph (1) unless it is includible under this paragraph.
+
+(b) Date of existence of power For purposes of this section, the power to alter, amend, revoke, or terminate shall be considered to exist on the date of the decedent’s death even though the exercise of the power is subject to a precedent giving of notice or even though the alteration, amendment, revocation, or termination takes effect only on the expiration of a stated period after the exercise of the power, whether or not on or before the date of the decedent’s death notice has been given or the power has been exercised. In such cases proper adjustment shall be made representing the interests which would have been excluded from the power if the decedent had lived, and for such purpose, if the notice has not been given or the power has not been exercised on or before the date of his death, such notice shall be considered to have been given, or the power exercised, on the date of his death.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 383; Pub. L. 86–141, § 1, Aug. 7, 1959, 73 Stat. 288; Pub. L. 87–834, § 18(a)(2)(F), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XIX, § 1902(a)(3), title XX, § 2001(c)(1)(K), Oct. 4, 1976, 90 Stat. 1804, 1852.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Subsec. (a)(1). Pub. L. 94–455, § 2001(c)(1)(K)(i), substituted “during the 3-year period ending on the date of the decedent’s death” for “in contemplation of decedent’s death”. Subsec. (a)(2). Pub. L. 94–455, § 2001(c)(1)(K)(ii), substituted “during the 3-year period ending on the date of the decedent’s death” for “in contemplation of his death”. Subsec. (c). Pub. L. 94–455, § 1902(a)(3), struck out subsec. (c) which covered the effect of a disability in certain cases by relating a mental disability to relinquish a power to a power, the relinquishment of which would be deemed not to be a transfer for purposes of chapter 4 of the Internal Revenue Code of 1939. 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States. 1959—Subsec. (c). Pub. L. 86–141 added subsec. (c).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(3) of Pub. L. 94–455 applicable to estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title. Amendment by section 2001(c)(1)(K)(i), (ii) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976 but not to transfers made before Jan. 1, 1977, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.
+
+Effective Date of 1959 AmendmentPub. L. 86–141, § 2, Aug. 7, 1959, 73 Stat. 289, provided that: “The amendment made by the first section of this Act [amending this section] shall apply only with respect to estates of decedents dying after August 16, 1954. No interest shall be allowed or paid on any overpayment resulting from the application of the amendment made by the first section of this Act with respect to any payment made before the date of the enactment of this Act [Aug. 7, 1959].”

legal/us/code/title-26/chapter-11/section-2040.md

@@ -0,0 +1,63 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2040"
+description: "Joint interests"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2040"
+citation: "26 U.S.C. § 2040"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2040"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "352f0a58b9001b36600007101c7931caa1f28f8a3bd6a7c483aef9ef29813583"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "bb7ca95f601f92172bcacbe8ff8c8ff99723402dc6ed26c9639e3a6f7f0304eb"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2040 - Joint interests
+
+## Text
+
+(a) General rule The value of the gross estate shall include the value of all property to the extent of the interest therein held as joint tenants with right of survivorship by the decedent and any other person, or as tenants by the entirety by the decedent and spouse, or deposited, with any person carrying on the banking business, in their joint names and payable to either or the survivor, except such part thereof as may be shown to have originally belonged to such other person and never to have been received or acquired by the latter from the decedent for less than an adequate and full consideration in money or money’s worth: Provided, That where such property or any part thereof, or part of the consideration with which such property was acquired, is shown to have been at any time acquired by such other person from the decedent for less than an adequate and full consideration in money or money’s worth, there shall be excepted only such part of the value of such property as is proportionate to the consideration furnished by such other person: Provided further, That where any property has been acquired by gift, bequest, devise, or inheritance, as a tenancy by the entirety by the decedent and spouse, then to the extent of one-half of the value thereof, or, where so acquired by the decedent and any other person as joint tenants with right of survivorship and their interests are not otherwise specified or fixed by law, then to the extent of the value of a fractional part to be determined by dividing the value of the property by the number of joint tenants with right of survivorship.
+
+(b) Certain joint interests of husband and wife (1) Interests of spouse excluded from gross estate Notwithstanding subsection (a), in the case of any qualified joint interest, the value included in the gross estate with respect to such interest by reason of this section is one-half of the value of such qualified joint interest.
+
+(2) Qualified joint interest defined For purposes of paragraph (1), the term “qualified joint interest” means any interest in property held by the decedent and the decedent’s spouse as—
+
+(A) tenants by the entirety, or
+
+(B) joint tenants with right of survivorship, but only if the decedent and the spouse of the decedent are the only joint tenants.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 385; Pub. L. 87–834, § 18(a)(2)(G), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XX, § 2002(c)(1), (3), Oct. 4, 1976, 90 Stat. 1855, 1856; Pub. L. 95–600, title V, § 511(a), title VII, § 702(k)(2), Nov. 6, 1978, 92 Stat. 2881, 2932; Pub. L. 96–222, title I, § 105(a)(3), Apr. 1, 1980, 94 Stat. 218; Pub. L. 97–34, title IV, § 403(c)(1)–(3)(A), Aug. 13, 1981, 95 Stat. 301, 302.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1981—Subsec. (a). Pub. L. 97–34, § 403(c)(2), substituted “joint tenants with right of survivorship” for “joint tenants” in three places. Subsec. (b)(2). Pub. L. 97–34, § 403(c)(1), in redefining “qualified joint interest” substituted provision defining term as meaning any interest in property held by the decedent and the decedent’s spouse as tenants by the entirety, or joint tenants with right of survivorship, but only if the decedent and the spouse of the decedent are the only joint tenants for provision defining the term as meaning any interest in property held by the decedent and the decedent’s spouse as joint tenants or as tenants by the entirety, but only if such joint interest was created by the decedent, the decedent’s spouse, or both, in the case of personal property, the creation of such joint interest constituted in whole or in part a gift for purposes of chapter 12, or in the case of real property, an election under section 2515 applies with respect to the creation of such joint interest, and in the case of a joint tenancy, only the decedent and the decedent’s spouse are joint tenants. Subsecs. (c) to (e). Pub. L. 97–34, § 403(c)(3)(A), repealed subsec. (c) respecting value where spouse of decedent materially participated in farm or other business, subsec. (d) relating to joint interests of husband and wife created before 1977, and subsec. (e) covering treatment of certain post-1976 terminations. 1980—Subsec. (c)(1). Pub. L. 96–222, § 105(a)(3)(B), substituted “subsection (a)” for “subsections (a)”. Subsec. (c)(2)(C). Pub. L. 96–222, § 105(a)(3)(A), added subpar. (C). 1978—Subsec. (c). Pub. L. 95–600, § 511(a), added subsec. (c). Subsecs. (d), (e). Pub. L. 95–600, § 702(k)(2), added subsecs. (d) and (e). 1976—Pub. L. 94–455 designated existing provisions as subsec. (a), added heading for subsec. (a), and added subsec. (b). 1962—Pub. L. 87–834 struck out provisions which excepted real property outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1981 AmendmentAmendment by Pub. L. 97–34 applicable to estates of decedents dying after Dec. 31, 1981, see section 403(e) of Pub. L. 97–34, set out as a note under section 2056 of this title.
+
+Effective Date of 1980 AmendmentAmendment by Pub. L. 96–222 effective, except as otherwise provided, as if it had been included in the provisions of the Revenue Act of 1978, Pub. L. 95–600, to which such amendment relates, see section 201 of Pub. L. 96–222, set out as a note under section 32 of this title.
+
+Effective Date of 1978 AmendmentPub. L. 95–600, title V, § 511(b), Nov. 6, 1978, 92 Stat. 2882, provided that: “The amendment made by subsection (a) [amending this section] shall apply with respect to estates of decedents dying after December 31, 1978.”
+
+Effective Date of 1976 AmendmentPub. L. 94–455, title XX, § 2002(d)(3), Oct. 4, 1976, 90 Stat. 1856, provided that: “The amendment made by subsection (c) [amending this section and section 2515 of this title] shall apply to joint interests created after December 31, 1976.”
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.
+
+Consideration Given Before July 14, 1988 by Decedent to Noncitizen Spouse Treated as Originally Belonging to SpousePub. L. 101–239, title VII, § 7815(d)(16), Dec. 19, 1989, 103 Stat. 2419, as amended by Pub. L. 101–508, title XI, § 11701(l)(3), Nov. 5, 1990, 104 Stat. 1388–513, provided that: “For purposes of applying section 2040(a) of the Internal Revenue Code of 1986 with respect to any joint interest to which section 2040(b) of such Code does not apply solely by reason of section 2056(d)(1)(B) of such Code, any consideration furnished before July 14, 1988, by the decedent for such interest to the extent treated as a gift to the spouse of the decedent for purposes of chapter 12 of such Code (or would have been so treated if the donor were a citizen of the United States) shall be treated as consideration originally belonging to such spouse and never acquired by such spouse from the decedent.”

legal/us/code/title-26/chapter-11/section-2041.md

@@ -0,0 +1,95 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2041"
+description: "Powers of appointment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2041"
+citation: "26 U.S.C. § 2041"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2041"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "8d32c3b78ea19000d778489e46169a3091631b85c98a2a9a57a539f98d7348a5"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "bc9faff0ff78dba5df5f232df8021c07af9329610189f5d5fd565f01c9fa4e21"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2041 - Powers of appointment
+
+## Text
+
+(a) In general The value of the gross estate shall include the value of all property—
+
+(1) Powers of appointment created on or before October 21, 1942 To the extent of any property with respect to which a general power of appointment created on or before October 21, 1942, is exercised by the decedent—
+
+(A) by will, or
+
+(B) by a disposition which is of such nature that if it were a transfer of property owned by the decedent, such property would be includible in the decedent’s gross estate under sections 2035 to 2038, inclusive;
+
+but the failure to exercise such a power or the complete release of such a power shall not be deemed an exercise thereof. If a general power of appointment created on or before October 21, 1942, has been partially released so that it is no longer a general power of appointment, the exercise of such power shall not be deemed to be the exercise of a general power of appointment if—
+
+(i) such partial release occurred before November 1, 1951, or
+
+(ii) the donee of such power was under a legal disability to release such power on October 21, 1942, and such partial release occurred not later than 6 months after the termination of such legal disability.
+
+(2) Powers created after October 21, 1942 To the extent of any property with respect to which the decedent has at the time of his death a general power of appointment created after October 21, 1942, or with respect to which the decedent has at any time exercised or released such a power of appointment by a disposition which is of such nature that if it were a transfer of property owned by the decedent, such property would be includible in the decedent’s gross estate under sections 2035 to 2038, inclusive. For purposes of this paragraph (2), the power of appointment shall be considered to exist on the date of the decedent’s death even though the exercise of the power is subject to a precedent giving of notice or even though the exercise of the power takes effect only on the expiration of a stated period after its exercise, whether or not on or before the date of the decedent’s death notice has been given or the power has been exercised.
+
+(3) Creation of another power in certain cases To the extent of any property with respect to which the decedent—
+
+(A) by will, or
+
+(B) by a disposition which is of such nature that if it were a transfer of property owned by the decedent such property would be includible in the decedent’s gross estate under section 2035, 2036, or 2037,
+
+exercises a power of appointment created after October 21, 1942, by creating another power of appointment which under the applicable local law can be validly exercised so as to postpone the vesting of any estate or interest in such property, or suspend the absolute ownership or power of alienation of such property, for a period ascertainable without regard to the date of the creation of the first power.
+
+(b) Definitions For purposes of subsection (a)—
+
+(1) General power of appointment The term “general power of appointment” means a power which is exercisable in favor of the decedent, his estate, his creditors, or the creditors of his estate; except that—
+
+(A) A power to consume, invade, or appropriate property for the benefit of the decedent which is limited by an ascertainable standard relating to the health, education, support, or maintenance of the decedent shall not be deemed a general power of appointment.
+
+(B) A power of appointment created on or before October 21, 1942, which is exercisable by the decedent only in conjunction with another person shall not be deemed a general power of appointment.
+
+(C) In the case of a power of appointment created after October 21, 1942, which is exercisable by the decedent only in conjunction with another person—
+
+(i) If the power is not exercisable by the decedent except in conjunction with the creator of the power—such power shall not be deemed a general power of appointment.
+
+(ii) If the power is not exercisable by the decedent except in conjunction with a person having a substantial interest in the property, subject to the power, which is adverse to exercise of the power in favor of the decedent—such power shall not be deemed a general power of appointment. For the purposes of this clause a person who, after the death of the decedent, may be possessed of a power of appointment (with respect to the property subject to the decedent’s power) which he may exercise in his own favor shall be deemed as having an interest in the property and such interest shall be deemed adverse to such exercise of the decedent’s power.
+
+(iii) If (after the application of clauses (i) and (ii)) the power is a general power of appointment and is exercisable in favor of such other person—such power shall be deemed a general power of appointment only in respect of a fractional part of the property subject to such power, such part to be determined by dividing the value of such property by the number of such persons (including the decedent) in favor of whom such power is exercisable.
+
+For purposes of clauses (ii) and (iii), a power shall be deemed to be exercisable in favor of a person if it is exercisable in favor of such person, his estate, his creditors, or the creditors of his estate.
+
+(2) Lapse of power The lapse of a power of appointment created after October 21, 1942, during the life of the individual possessing the power shall be considered a release of such power. The preceding sentence shall apply with respect to the lapse of powers during any calendar year only to the extent that the property, which could have been appointed by exercise of such lapsed powers, exceeded in value, at the time of such lapse, the greater of the following amounts:
+
+(A) $5,000, or
+
+(B) 5 percent of the aggregate value, at the time of such lapse, of the assets out of which, or the proceeds of which, the exercise of the lapsed powers could have been satisfied.
+
+(3) Date of creation of power For purposes of this section, a power of appointment created by a will executed on or before October 21, 1942, shall be considered a power created on or before such date if the person executing such will dies before July 1, 1949, without having republished such will, by codicil or otherwise, after October 21, 1942.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 385; Pub. L. 87–834, § 18(a)(2)(H), Oct. 16, 1962, 76 Stat. 1052; Pub. L. 94–455, title XX, § 2009(b)(4)(A), Oct. 4, 1976, 90 Stat. 1894.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Subsec. (a)(2). Pub. L. 94–455 struck out provision that a disclaimer or renunciation of a power of appointment not be deemed a release of that power. 1962—Subsec. (a). Pub. L. 87–834 struck out provisions which excepted real property situated outside of the United States.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to transfers creating an interest in person disclaiming made after Dec. 31, 1976, see section 2009(e)(2) of Pub. L. 94–455, set out as a note under section 2518 of this title.
+
+Effective Date of 1962 AmendmentAmendment by Pub. L. 87–834 applicable to estates of decedents dying after Oct. 16, 1962, except as otherwise provided, see section 18(b) of Pub. L. 87–834, set out as a note under section 2031 of this title.

legal/us/code/title-26/chapter-11/section-2042.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2042"
+description: "Proceeds of life insurance"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2042"
+citation: "26 U.S.C. § 2042"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2042"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "26c99182c353f419d91c98def4f048f8a320cea3312415aa0b845ee31abae15c"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "d68576b9cf3cacaa14abfebe59037568c809e363df815772e7242281741c7d79"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2042 - Proceeds of life insurance
+
+## Text
+
+The value of the gross estate shall include the value of all property—
+
+(1) Receivable by the executor To the extent of the amount receivable by the executor as insurance under policies on the life of the decedent.
+
+(2) Receivable by other beneficiaries To the extent of the amount receivable by all other beneficiaries as insurance under policies on the life of the decedent with respect to which the decedent possessed at his death any of the incidents of ownership, exercisable either alone or in conjunction with any other person. For purposes of the preceding sentence, the term “incident of ownership” includes a reversionary interest (whether arising by the express terms of the policy or other instrument or by operation of law) only if the value of such reversionary interest exceeded 5 percent of the value of the policy immediately before the death of the decedent. As used in this paragraph, the term “reversionary interest” includes a possibility that the policy, or the proceeds of the policy, may return to the decedent or his estate, or may be subject to a power of disposition by him. The value of a reversionary interest at any time shall be determined (without regard to the fact of the decedent’s death) by usual methods of valuation, including the use of tables of mortality and actuarial principles, pursuant to regulations prescribed by the Secretary. In determining the value of a possibility that the policy or proceeds thereof may be subject to a power of disposition by the decedent, such possibility shall be valued as if it were a possibility that such policy or proceeds may return to the decedent or his estate.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 387; Pub. L. 94–455, title XIX, § 1906(b)(13) (A), Oct. 4, 1976, 90 Stat. 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 struck out “or his delegate” after “Secretary”.

legal/us/code/title-26/chapter-11/section-2043.md

@@ -0,0 +1,49 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2043"
+description: "Transfers for insufficient consideration"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2043"
+citation: "26 U.S.C. § 2043"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2043"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "1b360e8786317725a06a53e09390f81a48be478b88ce53eb5a32bd39d03ad36d"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "f6d1fbdf7a131023d6b49da2f9c6a5a44c4e5cc06cc6ef0a8c47ca72b3b1e231"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2043 - Transfers for insufficient consideration
+
+## Text
+
+(a) In general If any one of the transfers, trusts, interests, rights, or powers enumerated and described in sections 2035 to 2038, inclusive, and section 2041 is made, created, exercised, or relinquished for a consideration in money or money’s worth, but is not a bona fide sale for an adequate and full consideration in money or money’s worth, there shall be included in the gross estate only the excess of the fair market value at the time of death of the property otherwise to be included on account of such transaction, over the value of the consideration received therefor by the decedent.
+
+(b) Marital rights not treated as consideration (1) In general For purposes of this chapter, a relinquishment or promised relinquishment of dower or curtesy, or of a statutory estate created in lieu of dower or curtesy, or of other marital rights in the decedent’s property or estate, shall not be considered to any extent a consideration “in money or money’s worth”.
+
+(2) Exception For purposes of section 2053 (relating to expenses, indebtedness, and taxes), a transfer of property which satisfies the requirements of paragraph (1) of section 2516 (relating to certain property settlements) shall be considered to be made for an adequate and full consideration in money or money’s worth.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 388; Pub. L. 98–369, div. A, title IV, § 425(a)(1), July 18, 1984, 98 Stat. 803.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1984—Subsec. (b). Pub. L. 98–369 amended subsec. (b) generally, designating existing provisions as par. (1) and adding par. (2).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1984 AmendmentPub. L. 98–369, div. A, title IV, § 425(c)(1), July 18, 1984, 98 Stat. 804, provided that: “The amendments made by subsection (a) [amending this section and section 2053 of this title] shall apply to estates of decedents dying after the date of the enactment of this Act [July 18, 1984].”

legal/us/code/title-26/chapter-11/section-2044.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2044"
+description: "Certain property for which marital deduction was previously allowed"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2044"
+citation: "26 U.S.C. § 2044"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2044"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "b0310a87b37ba5a524d8a3803add024c3484d839e608f9bffe7d45d2864ac7e7"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "c8d86257fe557161b2b3b5228d8701fcfe3f8d1666f65477719e4bc17482dfff"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2044 - Certain property for which marital deduction was previously allowed
+
+## Text
+
+(a) General rule The value of the gross estate shall include the value of any property to which this section applies in which the decedent had a qualifying income interest for life.
+
+(b) Property to which this section applies This section applies to any property if—
+
+(1) a deduction was allowed with respect to the transfer of such property to the decedent—
+
+(A) under section 2056 by reason of subsection (b)(7) thereof, or
+
+(B) under section 2523 by reason of subsection (f) thereof, and
+
+(2) section 2519 (relating to dispositions of certain life estates) did not apply with respect to a disposition by the decedent of part or all of such property.
+
+(c) Property treated as having passed from decedent For purposes of this chapter and chapter 13, property includible in the gross estate of the decedent under subsection (a) shall be treated as property passing from the decedent.
+
+(Added Pub. L. 97–34, title IV, § 403(d)(3)(A)(i), Aug. 13, 1981, 95 Stat. 304; amended Pub. L. 97–448, title I, § 104(a)(1)(B), Jan. 12, 1983, 96 Stat. 2380.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 2044 was renumbered section 2045 of this title.
+
+Amendments1983—Subsec. (c). Pub. L. 97–448 added subsec. (c).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1983 AmendmentAmendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.
+
+Effective DateSection applicable to estates of decedents dying after Dec. 31, 1981, see section 403(e) of Pub. L. 97–34, set out as an Effective Date of 1981 Amendment note under section 2056 of this title.

legal/us/code/title-26/chapter-11/section-2045.md

@@ -0,0 +1,47 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2045"
+description: "Prior interests"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2045"
+citation: "26 U.S.C. § 2045"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2045"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "e9f83ee26c28d6ae7cfd82e2a225b8f6c5a73debcea018ec94bd2e60ddc85d61"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "4d4f5a6044817b8e8f5b0a61150d4c6243ed0da4b445ca625034f878117d326c"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2045 - Prior interests
+
+## Text
+
+Except as otherwise specifically provided by law, sections 2034 to 2042, inclusive, shall apply to the transfers, trusts, estates, interests, rights, powers, and relinquishment of powers, as severally enumerated and described therein, whenever made, created, arising, existing, exercised, or relinquished.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 388, § 2044; Pub. L. 94–455, title XX, § 2001(c)(1)(M), Oct. 4, 1976, 90 Stat. 1853; renumbered § 2045, Pub. L. 97–34, title IV, § 403(d)(3)(A)(i), Aug. 13, 1981, 95 Stat. 304.)
+
+## Notes
+
+Editorial Notes
+
+Prior ProvisionsA prior section 2045 was renumbered section 2046 of this title.
+
+Amendments1976—Pub. L. 94–455 substituted “specifically provided by law” for “specifically provided therein”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d) of Pub. L. 94–455, set out as a note under section 2001 of this title.

legal/us/code/title-26/chapter-11/section-2046.md

@@ -0,0 +1,41 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2046"
+description: "Disclaimers"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2046"
+citation: "26 U.S.C. § 2046"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2046"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "064b4f3443ce60e032744c6e902ee4aa2836aefa073288b4d89c74d3fa11abe0"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "df158537f74863aaa34665cce2e9ae14f08b48c2962e1f7243ecacde638e4663"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2046 - Disclaimers
+
+## Text
+
+For provisions relating to the effect of a qualified disclaimer for purposes of this chapter, see section 2518.
+
+(Added Pub. L. 94–455, title XX, § 2009(b)(2), Oct. 4, 1976, 90 Stat. 1893, § 2045; renumbered § 2046, Pub. L. 97–34, title IV, § 403(d)(3)(A)(i), Aug. 13, 1981, 95 Stat. 304.)
+
+## Notes
+
+Statutory Notes and Related Subsidiaries
+
+Effective DateSection applicable to transfers creating an interest in person disclaiming made after Dec. 31, 1976, see section 2009(e)(2) of Pub. L. 94–455, set out as a note under section 2518 of this title.

legal/us/code/title-26/chapter-11/section-2051.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2051"
+description: "Definition of taxable estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2051"
+citation: "26 U.S.C. § 2051"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2051"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "3f8bd61fe667d48753ce79e3dede80f53995c5b86b3fd9eb247ae71132efa779"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "fe3c5fc0072b0cbc34ac45dbbcfc71017a3932648f16de364ed8cd27925a977d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2051 - Definition of taxable estate
+
+## Text
+
+For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate the deductions provided for in this part.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 388; Pub. L. 95–600, title VII, § 702(r)(2), Nov. 6, 1978, 92 Stat. 2938.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1978—Pub. L. 95–600 struck out “exemption and” after “gross estate the”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1978 AmendmentPub. L. 95–600, title VII, § 702(r)(5), Nov. 6, 1978, 92 Stat. 2939, provided that: “The amendments made by this subsection [amending this section and sections 1016, 6324B, and 6698A of this title] shall apply to estates of decedents dying after December 31, 1976.”

legal/us/code/title-26/chapter-11/section-2052.md

@@ -0,0 +1,37 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2052"
+description: "Repealed. Pub. L. 94–455, title XX, § 2001(a)(4), Oct. 4, 1976, 90 Stat. 1848]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2052"
+citation: "26 U.S.C. § 2052"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2052"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "8fba84e5708a50d278ba5d9b2494f7aabec9530f97215b244deef8f1264b3da5"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "33da09cd726bddab53b307aa119fbb5436f88abdc104ffcdd4eaf5997ba4b3d1"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2052 - Repealed. Pub. L. 94–455, title XX, § 2001(a)(4), Oct. 4, 1976, 90 Stat. 1848]
+
+## Notes
+
+Section, act Aug. 16, 1954, ch. 736, 68A Stat. 389, provided for an exemption of $60,000 to be deducted from gross estate in determining value of taxable estate.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as an Effective Date of 1976 Amendment note under section 2001 of this title.

legal/us/code/title-26/chapter-11/section-2053.md

@@ -0,0 +1,93 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2053"
+description: "Expenses, indebtedness, and taxes"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2053"
+citation: "26 U.S.C. § 2053"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2053"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "01a2c2d49fe75005466655c58d986520b3fa73a3f45d31cbe3bd6cf8691ae2af"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "eb2b14bbea9832b57963b860d502e0a454a18fa0457b911d59006e3e01d8fa46"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2053 - Expenses, indebtedness, and taxes
+
+## Text
+
+(a) General rule For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate such amounts—
+
+(1) for funeral expenses,
+
+(2) for administration expenses,
+
+(3) for claims against the estate, and
+
+(4) for unpaid mortgages on, or any indebtedness in respect of, property where the value of the decedent’s interest therein, undiminished by such mortgage or indebtedness, is included in the value of the gross estate,
+
+as are allowable by the laws of the jurisdiction, whether within or without the United States, under which the estate is being administered.
+
+(b) Other administration expenses Subject to the limitations in paragraph (1) of subsection (c), there shall be deducted in determining the taxable estate amounts representing expenses incurred in administering property not subject to claims which is included in the gross estate to the same extent such amounts would be allowable as a deduction under subsection (a) if such property were subject to claims, and such amounts are paid before the expiration of the period of limitation for assessment provided in section 6501.
+
+(c) Limitations (1) Limitations applicable to subsections (a) and (b) (A) Consideration for claims The deduction allowed by this section in the case of claims against the estate, unpaid mortgages, or any indebtedness shall, when founded on a promise or agreement, be limited to the extent that they were contracted bona fide and for an adequate and full consideration in money or money’s worth; except that in any case in which any such claim is founded on a promise or agreement of the decedent to make a contribution or gift to or for the use of any donee described in section 2055 for the purposes specified therein, the deduction for such claims shall not be so limited, but shall be limited to the extent that it would be allowable as a deduction under section 2055 if such promise or agreement constituted a bequest.
+
+(B) Certain taxes Any income taxes on income received after the death of the decedent, or property taxes not accrued before his death, or any estate, succession, legacy, or inheritance taxes, shall not be deductible under this section.
+
+(C) Certain claims by remaindermen No deduction shall be allowed under this section for a claim against the estate by a remainderman relating to any property described in section 2044.
+
+(D) Section 6166 interest No deduction shall be allowed under this section for any interest payable under section 6601 on any unpaid portion of the tax imposed by section 2001 for the period during which an extension of time for payment of such tax is in effect under section 6166.
+
+(2) Limitations applicable only to subsection (a) In the case of the amounts described in subsection (a), there shall be disallowed the amount by which the deductions specified therein exceed the value, at the time of the decedent’s death, of property subject to claims, except to the extent that such deductions represent amounts paid before the date prescribed for the filing of the estate tax return. For purposes of this section, the term “property subject to claims” means property includible in the gross estate of the decedent which, or the avails of which, would under the applicable law, bear the burden of the payment of such deductions in the final adjustment and settlement of the estate, except that the value of the property shall be reduced by the amount of the deduction under section 2054 attributable to such property.
+
+(d) Certain foreign death taxes (1) In general Notwithstanding the provisions of subsection (c)(1)(B), for purposes of the tax imposed by section 2001, the value of the taxable estate may be determined, if the executor so elects before the expiration of the period of limitation for assessment provided in section 6501, by deducting from the value of the gross estate the amount (as determined in accordance with regulations prescribed by the Secretary) of any estate, succession, legacy, or inheritance tax imposed by and actually paid to any foreign country, in respect of any property situated within such foreign country and included in the gross estate of a citizen or resident of the United States, upon a transfer by the decedent for public, charitable, or religious uses described in section 2055. The determination under this paragraph of the country within which property is situated shall be made in accordance with the rules applicable under subchapter B (sec. 2101 and following) in determining whether property is situated within or without the United States. Any election under this paragraph shall be exercised in accordance with regulations prescribed by the Secretary.
+
+(2) Condition for allowance of deduction No deduction shall be allowed under paragraph (1) for a foreign death tax specified therein unless the decrease in the tax imposed by section 2001 which results from the deduction provided in paragraph (1) will inure solely for the benefit of the public, charitable, or religious transferees described in section 2055 or section 2106(a)(2). In any case where the tax imposed by section 2001 is equitably apportioned among all the transferees of property included in the gross estate, including those described in sections 2055 and 2106(a)(2) (taking into account any exemptions, credits, or deductions allowed by this chapter), in determining such decrease, there shall be disregarded any decrease in the Federal estate tax which any transferees other than those described in sections 2055 and 2106(a)(2) are required to pay.
+
+(3) Effect on credit for foreign death taxes of deduction under this subsection (A) Election An election under this subsection shall be deemed a waiver of the right to claim a credit, against the Federal estate tax, under a death tax convention with any foreign country for any tax or portion thereof in respect of which a deduction is taken under this subsection.
+
+(B) Cross reference See section 2014(f) for the effect of a deduction taken under this paragraph on the credit for foreign death taxes.
+
+(e) Marital rights For provisions treating certain relinquishments of marital rights as consideration in money or money’s worth, see section 2043(b)(2).
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 389; Feb. 20, 1956, ch. 63, § 2, 70 Stat. 23; Pub. L. 85–866, title I, § 102(c)(3), Sept. 2, 1958, 72 Stat. 1674; Pub. L. 86–175, § 1, Aug. 21, 1959, 73 Stat. 396; Pub. L. 94–455, title XIX, §§ 1902(a)(12)(B), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1806, 1834; Pub. L. 98–369, div. A, title IV, § 425(a)(2), title X, § 1027(b), July 18, 1984, 98 Stat. 804, 1031; Pub. L. 100–647, title I, § 1011A(g)(11), Nov. 10, 1988, 102 Stat. 3482; Pub. L. 105–34, title V, § 503(b)(1), title X, § 1073(b)(3), Aug. 5, 1997, 111 Stat. 853, 948; Pub. L. 107–16, title V, § 532(c)(5), June 7, 2001, 115 Stat. 74; Pub. L. 107–134, title I, § 103(b)(2), Jan. 23, 2002, 115 Stat. 2431.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2002—Subsec. (d)(3)(B). Pub. L. 107–134 substituted “section 2011(d)” for “section 2011(e)”. 2001—Subsec. (d). Pub. L. 107–16 substituted “Certain foreign death taxes” for “Certain State and foreign death taxes” in heading and amended text generally, revising and restating provisions of pars. (1) to (3) so as to eliminate provisions relating to deduction for State death taxes. 1997—Subsec. (c)(1)(B). Pub. L. 105–34, § 1073(b)(3), struck out at end “This subparagraph shall not apply to any increase in the tax imposed by this chapter by reason of section 4980A(d).” Subsec. (c)(1)(D). Pub. L. 105–34, § 503(b)(1), added subpar. (D). 1988—Subsec. (c)(1)(B). Pub. L. 100–647, inserted at end “This subparagraph shall not apply to any increase in the tax imposed by this chapter by reason of section 4980A(d).” 1984—Subsec. (c)(1)(C). Pub. L. 98–369, § 1027(b), added subpar. (C). Subsec. (e). Pub. L. 98–369, § 425(a)(2), substituted “For provisions treating certain relinquishments of marital rights as consideration in money or money’s worth, see section 2043(b)(2)” for “For provisions that relinquishment of marital rights shall not be deemed a consideration ‘in money or money’s worth,’ see section 2043(b).” 1976—Subsec. (d)(1). Pub. L. 94–455 struck out “or his delegate” after “Secretary” in provisions preceding subpar. (A) and following subpar. (B) and struck out “or Territory” after “a State” in subpar. (A). 1959—Subsec. (d). Pub. L. 86–175 inserted a reference to foreign death taxes in heading of subsection and par. (3) and in text of par. (2), redesignated provisions of par. (1) as par. (1)(A) and sentence pertaining to exercise of privilege of election, added par. (2) and sentence for determining location of property, redesignated provisions of par. (3) as par. (3)(B) in part, and added par. (3)(A) and the part of (B) relating to foreign death taxes. 1958—Subsec. (d)(1). Pub. L. 85–866 struck out “or any possession of the United States,” after “District of Columbia,”. 1956—Subsecs. (d), (e). Act Feb. 20, 1956, added subsec. (d) and redesignated former subsec. (d) as (e).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2002 AmendmentPub. L. 107–134, title I, § 103(d), Jan. 23, 2002, 115 Stat. 2431, provided that: “(1) Effective date.—The amendments made by this section [amending this section and sections 2011 and 2201 of this title] shall apply to estates of decedents—“(A) dying on or after September 11, 2001; and “(B) in the case of individuals dying as a result of the April 19, 1995, terrorist attack, dying on or after April 19, 1995. “(2) Waiver of limitations.—If refund or credit of any overpayment of tax resulting from the amendments made by this section is prevented at any time before the close of the 1-year period beginning on the date of the enactment of this Act [Jan. 23, 2002] by the operation of any law or rule of law (including res judicata), such refund or credit may nevertheless be made or allowed if claim therefor is filed before the close of such period.”
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1997 AmendmentAmendment by section 503(b)(1) of Pub. L. 105–34 applicable to estates of decedents dying after Dec. 31, 1997, with special rule in case of estate of any decedent dying before Jan. 1, 1998, with respect to which there is an election under section 6166 of this title, see section 503(d) of Pub. L. 105–34, set out as a note under section 163 of this title. Amendment by section 1073(b)(3) of Pub. L. 105–34 applicable to estates of decedents dying after Dec. 31, 1996, see section 1073(c) of Pub. L. 105–34, set out as an Effective Date of Repeal note under section 4980A of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective Date of 1984 AmendmentAmendment by section 425(a)(2) of Pub. L. 98–369 applicable to estates of decedents dying after July 18, 1984, see section 425(c)(1) of Pub. L. 98–369, set out as a note under section 2043 of this title. Pub. L. 98–369, div. A, title X, § 1027(c), July 18, 1984, 98 Stat. 1032, provided that: “The amendments made by this section [amending this section and section 2056 of this title] shall take effect as if included in the amendment made by section 403 of the Economic Recovery Tax Act of 1981 [section 403 of Pub. L. 97–34, see Effective Date of 1981 Amendment note set out under section 2056 of this title].”
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(12)(B) of Pub. L. 94–455 applicable to estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title.
+
+Effective Date of 1959 AmendmentPub. L. 86–175, § 4, Aug. 21, 1959, 73 Stat. 397, provided that: “The amendments made by the preceding sections of this Act [amending this section and sections 2011 and 2014 of this title] shall apply with respect to the estates of decedents dying on or after July 1, 1955.”
+
+Effective Date of 1958 AmendmentAmendment by Pub. L. 85–866 applicable to estates of decedents dying after Sept. 2, 1958, see section 102(d) of Pub. L. 85–866, set out as a note under section 2014 of this title.
+
+Effective Date of 1956 AmendmentAct Feb. 20, 1956, ch. 63, § 4, 70 Stat. 25, as amended by act Oct. 22, 1986, Pub. L. 99–514, § 2, 100 Stat. 2095, provided that: “The amendments to the Internal Revenue Code of 1986 [formerly I.R.C. 1954] made by sections 2 and 3 of this Act [amending this section and section 2011 of this title], and provisions having the same effect as this amendment, which shall be considered to be included in chapter 3 of the Internal Revenue Code of 1939, shall apply to the estates of all decedents dying after December 31, 1953.”

legal/us/code/title-26/chapter-11/section-2054.md

@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2054"
+description: "Losses"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2054"
+citation: "26 U.S.C. § 2054"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2054"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "69df2eace0550ec153fef1199cfbc69e4563b949ec5753d3996ef9c06c840e50"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "069b63abd1474df99f38ff0f37f2d0eac0d26717a98050a3e178693e1681b28e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2054 - Losses
+
+## Text
+
+For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate losses incurred during the settlement of estates arising from fires, storms, shipwrecks, or other casualties, or from theft, when such losses are not compensated for by insurance or otherwise.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 390.)

legal/us/code/title-26/chapter-11/section-2056a.md

@@ -0,0 +1,161 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2056A"
+description: "Qualified domestic trust"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2056A"
+citation: "26 U.S.C. § 2056A"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2056A"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "b88c1487ca56aaae6e59e8f5b189e1e0f06b3c8aca38d3e6071c13e15759da9f"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "c4026e3b4cdd657702367bec039565acd9919ae7f2d0911414bdf787ca49a2ce"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2056A - Qualified domestic trust
+
+## Text
+
+(a) Qualified domestic trust defined For purposes of this section and section 2056(d), the term “qualified domestic trust” means, with respect to any decedent, any trust if—
+
+(1) the trust instrument—
+
+(A) except as provided in regulations prescribed by the Secretary, requires that at least 1 trustee of the trust be an individual citizen of the United States or a domestic corporation, and
+
+(B) provides that no distribution (other than a distribution of income) may be made from the trust unless a trustee who is an individual citizen of the United States or a domestic corporation has the right to withhold from such distribution the tax imposed by this section on such distribution,
+
+(2) such trust meets such requirements as the Secretary may by regulations prescribe to ensure the collection of any tax imposed by subsection (b), and
+
+(3) an election under this section by the executor of the decedent applies to such trust.
+
+(b) Tax treatment of trust (1) Imposition of estate tax There is hereby imposed an estate tax on—
+
+(A) any distribution before the date of the death of the surviving spouse from a qualified domestic trust, and
+
+(B) the value of the property remaining in a qualified domestic trust on the date of the death of the surviving spouse.
+
+(2) Amount of tax (A) In general In the case of any taxable event, the amount of the estate tax imposed by paragraph (1) shall be the amount equal to—
+
+(i) the tax which would have been imposed under section 2001 on the estate of the decedent if the taxable estate of the decedent had been increased by the sum of—
+
+(I) the amount involved in such taxable event, plus
+
+(II) the aggregate amount involved in previous taxable events with respect to qualified domestic trusts of such decedent, reduced by
+
+(ii) the tax which would have been imposed under section 2001 on the estate of the decedent if the taxable estate of the decedent had been increased by the amount referred to in clause (i)(II).
+
+(B) Tentative tax where tax of decedent not finally determined (i) In general If the tax imposed on the estate of the decedent under section 2001 is not finally determined before the taxable event, the amount of the tax imposed by paragraph (1) on such event shall be determined by using the highest rate of tax in effect under section 2001 as of the date of the decedent’s death.
+
+(ii) Refund of excess when tax finally determined If—
+
+(I) the amount of the tax determined under clause (i), exceeds
+
+(II) the tax determined under subparagraph (A) on the basis of the final determination of the tax imposed by section 2001 on the estate of the decedent,
+
+such excess shall be allowed as a credit or refund (with interest) if claim therefor is filed not later than 1 year after the date of such final determination.
+
+(C) Special rule where decedent has more than 1 qualified domestic trust If there is more than 1 qualified domestic trust with respect to any decedent, the amount of the tax imposed by paragraph (1) with respect to such trusts shall be determined by using the highest rate of tax in effect under section 2001 as of the date of the decedent’s death (and the provisions of paragraph (3)(B) shall not apply) unless, pursuant to a designation made by the decedent’s executor, there is 1 person—
+
+(i) who is an individual citizen of the United States or a domestic corporation and is responsible for filing all returns of tax imposed under paragraph (1) with respect to such trusts and for paying all tax so imposed, and
+
+(ii) who meets such requirements as the Secretary may by regulations prescribe.
+
+(3) Certain lifetime distributions exempt from tax (A) Income distributions No tax shall be imposed by paragraph (1)(A) on any distribution of income to the surviving spouse.
+
+(B) Hardship exemption No tax shall be imposed by paragraph (1)(A) on any distribution to the surviving spouse on account of hardship.
+
+(4) Tax where trust ceases to qualify If any qualified domestic trust ceases to meet the requirements of paragraphs (1) and (2) of subsection (a), the tax imposed by paragraph (1) shall apply as if the surviving spouse died on the date of such cessation.
+
+(5) Due date (A) Tax on distributions The estate tax imposed by paragraph (1)(A) shall be due and payable on the 15th day of the 4th month following the calendar year in which the taxable event occurs; except that the estate tax imposed by paragraph (1)(A) on distributions during the calendar year in which the surviving spouse dies shall be due and payable not later than the date on which the estate tax imposed by paragraph (1)(B) is due and payable.
+
+(B) Tax at death of spouse The estate tax imposed by paragraph (1)(B) shall be due and payable on the date 9 months after the date of such death.
+
+(6) Liability for tax Each trustee shall be personally liable for the amount of the tax imposed by paragraph (1). Rules similar to the rules of section 2204 shall apply for purposes of the preceding sentence.
+
+(7) Treatment of tax For purposes of section 2056(d), any tax paid under paragraph (1) shall be treated as a tax paid under section 2001 with respect to the estate of the decedent.
+
+(8) Lien for tax For purposes of section 6324, any tax imposed by paragraph (1) shall be treated as an estate tax imposed under this chapter with respect to a decedent dying on the date of the taxable event (and the property involved shall be treated as the gross estate of such decedent).
+
+(9) Taxable event The term “taxable event” means the event resulting in tax being imposed under paragraph (1).
+
+(10) Certain benefits allowed (A) In general If any property remaining in the qualified domestic trust on the date of the death of the surviving spouse is includible in the gross estate of such spouse for purposes of this chapter (or would be includible if such spouse were a citizen or resident of the United States), any benefit which is allowable (or would be allowable if such spouse were a citizen or resident of the United States) with respect to such property to the estate of such spouse under section 2014, 2032, 2032A, 2055, 2056, 2058, or 6166 shall be allowed for purposes of the tax imposed by paragraph (1)(B).
+
+(B) Section 303 If the estate of the surviving spouse meets the requirements of section 303 with respect to any property described in subparagraph (A), for purposes of section 303, the tax imposed by paragraph (1)(B) with respect to such property shall be treated as a Federal estate tax payable with respect to the estate of the surviving spouse.
+
+(C) Section 6161(a)(2) The provisions of section 6161(a)(2) shall apply with respect to the tax imposed by paragraph (1)(B), and the reference in such section to the executor shall be treated as a reference to the trustees of the trust.
+
+(11) Special rule where distribution tax paid out of trust For purposes of this subsection, if any portion of the tax imposed by paragraph (1)(A) with respect to any distribution is paid out of the trust, an amount equal to the portion so paid shall be treated as a distribution described in paragraph (1)(A).
+
+(12) Special rule where spouse becomes citizen If the surviving spouse of the decedent becomes a citizen of the United States and if—
+
+(A) such spouse was a resident of the United States at all times after the date of the death of the decedent and before such spouse becomes a citizen of the United States,
+
+(B) no tax was imposed by paragraph (1)(A) with respect to any distribution before such spouse becomes such a citizen, or
+
+(C) such spouse elects—
+
+(i) to treat any distribution on which tax was imposed by paragraph (1)(A) as a taxable gift made by such spouse for purposes of—
+
+(I) section 2001, and
+
+(II) determining the amount of the tax imposed by section 2501 on actual taxable gifts made by such spouse during the year in which the spouse becomes a citizen or any subsequent year, and
+
+(ii) to treat any reduction in the tax imposed by paragraph (1)(A) by reason of the credit allowable under section 2010 with respect to the decedent as a credit allowable to such surviving spouse under section 2505 for purposes of determining the amount of the credit allowable under section 2505 with respect to taxable gifts made by the surviving spouse during the year in which the spouse becomes a citizen or any subsequent year,
+
+paragraph (1)(A) shall not apply to any distributions after such spouse becomes such a citizen (and paragraph (1)(B) shall not apply).
+
+(13) Coordination with section 1015 For purposes of section 1015, any distribution on which tax is imposed by paragraph (1)(A) shall be treated as a transfer by gift, and any tax paid under paragraph (1)(A) shall be treated as a gift tax.
+
+(14) Coordination with terminable interest rules Any interest in a qualified domestic trust shall not be treated as failing to meet the requirements of paragraph (5) or (7) of section 2056(b) merely by reason of any provision of the trust instrument permitting the withholding from any distribution of an amount to pay the tax imposed by paragraph (1) on such distribution.
+
+(15) No tax on certain distributions No tax shall be imposed by paragraph (1) on any distribution to the surviving spouse to the extent such distribution is to reimburse such surviving spouse for any tax imposed by subtitle A on any item of income of the trust to which such surviving spouse is not entitled under the terms of the trust.
+
+(c) Definitions For purposes of this section—
+
+(1) Property includes interest therein The term “property” includes an interest in property.
+
+(2) Income Except as provided in regulations, the term “income” has the meaning given to such term by section 643(b).
+
+(3) Trust To the extent provided in regulations prescribed by the Secretary, the term “trust” includes other arrangements which have substantially the same effect as a trust.
+
+(d) Election An election under this section with respect to any trust shall be made by the executor on the return of the tax imposed by section 2001. Such an election, once made, shall be irrevocable. No election may be made under this section on any return if such return is filed more than one year after the time prescribed by law (including extensions) for filing such return.
+
+(e) Regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this section, including regulations under which there may be treated as a qualified domestic trust any annuity or other payment which is includible in the decedent’s gross estate and is by its terms payable for life or a term of years.
+
+(Added Pub. L. 100–647, title V, § 5033(a)(2), Nov. 10, 1988, 102 Stat. 3670; amended Pub. L. 101–239, title VII, § 7815(d)(7), (9)–(13), (15), Dec. 19, 1989, 103 Stat. 2415–2418; Pub. L. 101–508, title XI, §§ 11702(g)(2)(A), (B), (3)(A), (4), 11704(a)(15), Nov. 5, 1990, 104 Stat. 1388–515, 1388–516, 1388–518; Pub. L. 105–34, title XIII, §§ 1312(a), 1314(a), Aug. 5, 1997, 111 Stat. 1044, 1045; Pub. L. 107–16, title V, § 532(c)(6), June 7, 2001, 115 Stat. 74.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Subsec. (b)(10)(A). Pub. L. 107–16 struck out “2011,” before “2014,” and inserted “2058,” after “2056,”. 1997—Subsec. (a)(1)(A). Pub. L. 105–34, § 1314(a), inserted “except as provided in regulations prescribed by the Secretary,” before “requires”. Subsec. (c)(3). Pub. L. 105–34, § 1312(a), added par. (3). 1990—Subsec. (a)(1). Pub. L. 101–508, § 11702(g)(2)(A), amended par. (1) generally. Prior to amendment, par. (1) read as follows: “the trust instrument requires that at least 1 trustee of the trust be an individual citizen of the United States or a domestic corporation and that no distribution from the trust may be made without the approval of such a trustee,”. Subsec. (b)(2)(B)(ii). Pub. L. 101–508, § 11704(a)(15), substituted “therefor” for “therefore” in concluding provisions. Subsec. (b)(10)(A). Pub. L. 101–508, § 11702(g)(4), substituted “section 2011, 2014, 2032” for “section 2032”. Subsec. (b)(14), (15). Pub. L. 101–508, § 11702(g)(2)(B), added pars. (14) and (15). Subsec. (d). Pub. L. 101–508, § 11702(g)(3)(A), inserted at end “No election may be made under this section on any return if such return is filed more than one year after the time prescribed by law (including extensions) for filing such return.” 1989—Subsec. (a)(1). Pub. L. 101–239, § 7815(d)(7)(A)(i), amended par. (1) generally. Prior to amendment, par. (1) read as follows: “the trust instrument requires that all trustees of the trust be individual citizens of the United States or domestic corporations,”. Subsec. (a)(2) to (4). Pub. L. 101–239, § 7815(d)(7)(A)(ii), redesignated pars. (3) and (4) as (2) and (3), respectively, and struck out former par. (2) which read as follows: “the surviving spouse of the decedent is entitled to all the income from the property in such trust, payable annually or at more frequent intervals,”. Subsec. (b)(1)(A). Pub. L. 101–239, § 7815(d)(7)(C), struck out “other than a distribution of income required under subsection (a)(2)” after “qualified domestic trust”. Subsec. (b)(2)(B)(ii). Pub. L. 101–239, § 7815(d)(11), inserted “(with interest)” after “credit or refund”. Subsec. (b)(2)(C). Pub. L. 101–239, § 7815(d)(12), added subpar. (C). Subsec. (b)(3). Pub. L. 101–239, § 7815(d)(7)(B), added par. (3). Former par. (3) redesignated (4). Subsec. (b)(4). Pub. L. 101–239, § 7815(d)(7)(D), amended par. (4) generally. Prior to amendment, par. (4) read as follows: “If any person other than an individual citizen of the United States or a domestic corporation becomes a trustee of a qualified domestic trust (or such trust ceases to meet the requirements of subsection (a)(3)), the tax imposed by paragraph (1) shall apply as if the surviving spouse died on the date on which such person became such a trustee or the date of such cessation, as the case may be.” Pub. L. 101–239, § 7815(d)(7)(B), redesignated par. (3) as (4). Former par. (4) redesignated (5). Subsec. (b)(5). Pub. L. 101–239, § 7815(d)(15), amended par. (5) generally. Prior to amendment, par. (5) read as follows: “The estate tax imposed by paragraph (1) shall be due and payable on the 15th day of the 4th month following the calendar year in which the taxable event occurs.” Pub. L. 101–239, § 7815(d)(7)(B), redesignated par. (4) as (5). Former par. (5) redesignated (6). Subsec. (b)(6) to (9). Pub. L. 101–239, § 7815(d)(7)(B), redesignated pars. (5) to (8) as (6) to (9), respectively. Subsec. (b)(10) to (13). Pub. L. 101–239, § 7815(d)(9), added pars. (10) to (13). Subsec. (c)(2). Pub. L. 101–239, § 7815(d)(10), substituted “Except as provided in regulations, the term” for “The term”. Subsec. (e). Pub. L. 101–239, § 7815(d)(13), added subsec. (e).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1997 AmendmentPub. L. 105–34, title XIII, § 1312(b), Aug. 5, 1997, 111 Stat. 1045, provided that: “The amendment made by this section [amending this section] shall apply to estates of decedents dying after the date of the enactment of this Act [Aug. 5, 1997].” Pub. L. 105–34, title XIII, § 1314(b), Aug. 5, 1997, 111 Stat. 1045, provided that: “The amendment made by this section [amending this section] shall apply to estates of decedents dying after the date of the enactment of this Act [Aug. 5, 1997].”
+
+Effective Date of 1990 AmendmentAmendment by section 11702(g)(2), (4) of Pub. L. 101–508 effective as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 11702(j) of Pub. L. 101–508, set out as a note under section 59 of this title. Pub. L. 101–508, title XI, § 11702(g)(3)(B), Nov. 5, 1990, 104 Stat. 1388–516, provided that: “The amendment made by subparagraph (A) [amending this section] shall not apply to any election made before the date 6 months after the date of the enactment of this Act [Nov. 5, 1990].”
+
+Effective Date of 1989 AmendmentAmendment by Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
+
+Effective DateSection applicable to estates of decedents dying after Nov. 10, 1988, see section 5033(d)(1) of Pub. L. 100–647, set out as an Effective Date of 1988 Amendment note under section 2056 of this title.
+
+Transitional RulePub. L. 105–34, title XIII, § 1303, Aug. 5, 1997, 111 Stat. 1039, provided that: “(a) General Rule.—In the case of any trust created under an instrument executed before the date of the enactment of the Revenue Reconciliation Act of 1990 [Nov. 5, 1990], such trust shall be treated as meeting the requirements of paragraph (1) of section 2056A(a) of the Internal Revenue Code of 1986 if the trust instrument requires that all trustees of the trust be individual citizens of the United States or domestic corporations. “(b) Effective Date.—The provisions of subsection (a) shall take effect as if included in the provisions of section 11702(g) of the Revenue Reconciliation Act of 1990 [Pub. L. 101–508].”
+
+Application of Amendments by Section 5033 of Pub. L. 100–647 to Estates of, or Gifts by, Noncitizen and Nonresident IndividualsFor provisions directing that in the case of the estate of, or gift by, an individual who was not a citizen or resident of the United States but was a resident of a foreign country with which the United States has a tax treaty with respect to estate, inheritance, or gift taxes, this section shall not apply to the extent such section would be inconsistent with the provisions of such treaty relating to estate, inheritance, or gift tax marital deductions, but that in the case of the estate of an individual dying before the date 3 years after Dec. 19, 1989, or a gift by an individual before the date 3 years after Dec. 19, 1989, the requirement of the preceding provision that the individual not be a citizen or resident of the United States shall not apply, see section 7815(d)(14) of Pub. L. 101–239, set out as a note under section 2056 of this title.

legal/us/code/title-26/chapter-11/section-2057.md

@@ -0,0 +1,41 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2057"
+description: "Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(97)(A), Dec. 19, 2014, 128 Stat. 4051]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2057"
+citation: "26 U.S.C. § 2057"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2057"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "09523324eb2bc2d7ef689e8739f032c88dc3183210dba7c866708d7ccefe516d"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "9db2aed66e5e6e4b5d02e262f461c03f6df01e0b91f14c2178fe32e9f68c9293"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2057 - Repealed. Pub. L. 113–295, div. A, title II, § 221(a)(97)(A), Dec. 19, 2014, 128 Stat. 4051]
+
+## Notes
+
+Section, added Pub. L. 105–34, title V, § 502(a), Aug. 5, 1997, 111 Stat. 847, § 2033A; renumbered § 2057 and amended Pub. L. 105–206, title VI, § 6007(b)(1)(A)–(D), (2)–(7), July 22, 1998, 112 Stat. 807–809; Pub. L. 107–16, title V, § 521(d), June 7, 2001, 115 Stat. 72; Pub. L. 108–311, title II, § 207(23), Oct. 4, 2004, 118 Stat. 1178, related to deduction for qualified family-owned business interests of a decedent.
+
+A prior section 2057, added Pub. L. 99–514, title XI, § 1172(a), Oct. 22, 1986, 100 Stat. 2513; amended Pub. L. 100–203, title X, §§ 10411(a), 10412(a), Dec. 22, 1987, 101 Stat. 1330–432, 1330–433; Pub. L. 100–647, title I, § 1011B(g)(3), Nov. 10, 1988, 102 Stat. 3490, related to sales of employer securities to employee stock ownership plans or worker-owned cooperatives, prior to repeal by Pub. L. 101–239, title VII, § 7304(a)(1), (3), Dec. 19, 1989, 103 Stat. 2352, 2353, applicable to estates of decedents dying after Dec. 19, 1989.
+
+Another prior section 2057, added Pub. L. 94–455, title XX, § 2007(a), Oct. 4, 1976, 90 Stat. 1890; amended Pub. L. 95–600, title VII, § 702(l)(1), (2), Nov. 6, 1978, 92 Stat. 2934, 2935, related to bequests, etc., to certain minor children, prior to repeal by Pub. L. 97–34, title IV, § 427(a), (c), Aug. 13, 1981, 95 Stat. 3181, applicable to estates of decedents dying after Dec. 31, 1981.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as an Effective Date of 2014 Amendment note under section 1 of this title.

legal/us/code/title-26/chapter-11/section-2058.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2058"
+description: "State death taxes"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2058"
+citation: "26 U.S.C. § 2058"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2058"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "27f9c5d4c8f0e2bada10cd0cac49a924e6c8d98413424bafdc24dd4b8b79c0e3"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e01ebc16a2285c3b820be977cc159f612a0799ad6ff2d3c026c6f73bfedf6cfb"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2058 - State death taxes
+
+## Text
+
+(a) Allowance of deduction For purposes of the tax imposed by section 2001, the value of the taxable estate shall be determined by deducting from the value of the gross estate the amount of any estate, inheritance, legacy, or succession taxes actually paid to any State or the District of Columbia, in respect of any property included in the gross estate (not including any such taxes paid with respect to the estate of a person other than the decedent).
+
+(b) Period of limitations The deduction allowed by this section shall include only such taxes as were actually paid and deduction therefor claimed before the later of—
+
+(1) 4 years after the filing of the return required by section 6018, or
+
+(2) if—
+
+(A) a petition for redetermination of a deficiency has been filed with the Tax Court within the time prescribed in section 6213(a), the expiration of 60 days after the decision of the Tax Court becomes final,
+
+(B) an extension of time has been granted under section 6161 or 6166 for payment of the tax shown on the return, or of a deficiency, the date of the expiration of the period of the extension, or
+
+(C) a claim for refund or credit of an overpayment of tax imposed by this chapter has been filed within the time prescribed in section 6511, the latest of the expiration of—
+
+(i) 60 days from the date of mailing by certified mail or registered mail by the Secretary to the taxpayer of a notice of the disallowance of any part of such claim,
+
+(ii) 60 days after a decision by any court of competent jurisdiction becomes final with respect to a timely suit instituted upon such claim, or
+
+(iii) 2 years after a notice of the waiver of disallowance is filed under section 6532(a)(3).
+
+Notwithstanding sections 6511 and 6512, refund based on the deduction may be made if the claim for refund is filed within the period provided in the preceding sentence. Any such refund shall be made without interest.
+
+(Added Pub. L. 107–16, title V, § 532(b), June 7, 2001, 115 Stat. 73.)
+
+## Notes
+
+Statutory Notes and Related Subsidiaries
+
+Effective DateSection applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as an Effective Date of 2001 Amendment note under section 2012 of this title.

legal/us/code/title-26/chapter-11/section-2101.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2101"
+description: "Tax imposed"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2101"
+citation: "26 U.S.C. § 2101"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2101"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "cafeb589d97e2e9cc80b44ad3c83510d67195c83231b38f2c2093eaf78131a60"
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+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2101 - Tax imposed
+
+## Text
+
+(a) 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.
+
+(b) Computation of tax The tax imposed by this section shall be the amount equal to the excess (if any) of—
+
+(1) a tentative tax computed under section 2001(c) on the sum of—
+
+(A) the amount of the taxable estate, and
+
+(B) the amount of the adjusted taxable gifts, over
+
+(2) a tentative tax computed under section 2001(c) on the amount of the adjusted taxable gifts.
+
+(c) Adjustments for taxable gifts (1) 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 December 31, 1976, other than gifts which are includible in the gross estate of the decedent.
+
+(2) Adjustment for certain gift tax For purposes of this section, the rules of section 2001(d) shall apply.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 397; Pub. L. 89–809, title I, § 108(a), Nov. 13, 1966, 80 Stat. 1571; Pub. L. 94–455, title XX, § 2001(c)(1)(D), Oct. 4, 1976, 90 Stat. 1850; Pub. L. 100–647, title V, § 5032(a), (c), Nov. 10, 1988, 102 Stat. 3669; Pub. L. 101–239, title VII, § 7815(c), Dec. 19, 1989, 103 Stat. 2415; Pub. L. 103–66, title XIII, § 13208(b)(3), Aug. 10, 1993, 107 Stat. 469; Pub. L. 107–147, title IV, § 411(g)(2), Mar. 9, 2002, 116 Stat. 46.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2002—Subsec. (b). Pub. L. 107–147 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.” 1993—Subsec. (b). Pub. L. 103–66 substituted “section 2001(c)(2)” for “section 2001(c)(3)” in last sentence. 1989—Subsec. (b). Pub. L. 101–239 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.” 1988—Subsec. (b). Pub. L. 100–647, § 5032(a), 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). Subsec. (d). Pub. L. 100–647, § 5032(c), struck out subsec. (d) which provided a rate schedule. 1976—Pub. L. 94–455 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. 1966—Subsec. (a). Pub. L. 89–809 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 AmendmentAmendment by Pub. L. 107–147 effective as if included in the provisions of the Economic Growth and Tax Relief Reconciliation Act of 2001, Pub. L. 107–16, to which such amendment relates, see section 411(x) of Pub. L. 107–147, set out as a note under section 25B of this title.
+
+Effective Date of 1993 AmendmentAmendment by Pub. L. 103–66 applicable in the case of decedents dying and gifts made after Dec. 31, 1992, see section 13208(c) of Pub. L. 103–66, set out as a note under section 2001 of this title.
+
+Effective Date of 1989 AmendmentAmendment by Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
+
+Effective Date of 1988 AmendmentPub. L. 100–647, title V, § 5032(d), Nov. 10, 1988, 102 Stat. 3670, provided that: “The amendments made by this section [amending this section and section 2102 of this title] shall apply to the estates of decedents dying after the date of the enactment of this Act [Nov. 10, 1988].”
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1966 AmendmentPub. L. 89–809, title I, § 108(i), Nov. 13, 1966, 80 Stat. 1574, provided that: “The amendments made by this section [amending this section and sections 2102, 2104, 2105, 2106, and 6018 of this title and enacting sections 2107 and 2108 of this title] shall apply with respect to estates of decedents dying after the date of the enactment of this Act [Nov. 13, 1966].”

legal/us/code/title-26/chapter-11/section-2102.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2102"
+description: "Credits against tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2102"
+citation: "26 U.S.C. § 2102"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2102"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "f24187ad1ce0f7fe4a3cc7b14ee3d5076a1f16bfeafcd9e9ffcb92eab81d406b"
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+text_hash: "c5976aa536f5efeb1d57bc1e8cc16fa9a96e06be582ad703fbb92b8667fffb9c"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2102 - Credits against tax
+
+## Text
+
+(a) In general The tax imposed by section 2101 shall be credited with the amounts determined in accordance with sections 2012 and 2013 (relating to gift tax and tax on prior transfers).
+
+(b) Unified credit (1) In general A credit of $13,000 shall be allowed against the tax imposed by section 2101.
+
+(2) Residents of possessions of the United States In the case of a decedent who is considered to be a “nonresident not a citizen of the United States” under section 2209, the credit under this subsection shall be the greater of—
+
+(A) $13,000, or
+
+(B) that proportion of $46,800 which the value of that part of the decedent’s gross estate which at the time of his death is situated in the United States bears to the value of his entire gross estate wherever situated.
+
+(3) Special rules (A) Coordination with treaties To the extent required under any treaty obligation of the United States, the credit allowed under this subsection shall be equal to the amount which bears the same ratio to the applicable credit amount in effect under section 2010(c) for the calendar year which includes the date of death as the value of the part of the decedent’s gross estate which at the time of his death is situated in the United States bears to the value of his entire gross estate wherever situated. For purposes of the preceding sentence, property shall not be treated as situated in the United States if such property is exempt from the tax imposed by this subchapter under any treaty obligation of the United States.
+
+(B) Coordination with gift tax unified credit If a credit has been allowed under section 2505 with respect to any gift made by the decedent, each dollar amount contained in paragraph (1) or (2) or subparagraph (A) of this paragraph (whichever applies) shall be reduced by the amount so allowed.
+
+(4) Limitation based on amount of tax The credit allowed under this subsection shall not exceed the amount of the tax imposed by section 2101.
+
+(5) Application of other credits For purposes of subsection (a), sections 2012 and 2013 shall be applied as if the credit allowed under this subsection were allowed under section 2010.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 397; Pub. L. 89–809, title I, § 108(b), Nov. 13, 1966, 80 Stat. 1572; Pub. L. 94–455, title XX, § 2001(c)(1)(E)(i), Oct. 4, 1976, 90 Stat. 1851; Pub. L. 100–647, title V, § 5032(b), Nov. 10, 1988, 102 Stat. 3669; Pub. L. 104–188, title I, § 1704(f)(1), Aug. 20, 1996, 110 Stat. 1879; Pub. L. 105–34, title V, § 501(a)(1)(E), Aug. 5, 1997, 111 Stat. 845; Pub. L. 107–16, title V, § 532(c)(7), June 7, 2001, 115 Stat. 75.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2001—Subsec. (a). Pub. L. 107–16, § 532(c)(7)(A), reenacted heading without change and amended text of subsec. (a) generally. Prior to amendment, text read as follows: “The tax imposed by section 2101 shall be credited with the amounts determined in accordance with sections 2011 to 2013, inclusive (relating to State death taxes, gift tax, and tax on prior transfers), subject to the special limitation provided in subsection (b).” Subsec. (b). Pub. L. 107–16, § 532(c)(7)(B), redesignated subsec. (c) as (b) and struck out heading and text of former subsec. (b). Text read as follows: “The maximum credit allowed under section 2011 against the tax imposed by section 2101 for State death taxes paid shall be an amount which bears the same ratio to the credit computed as provided in section 2011(b) as the value of the property, as determined for purposes of this chapter, upon which State death taxes were paid and which is included in the gross estate under section 2103 bears to the value of the total gross estate under section 2103. For purposes of this subsection, the term ‘State death taxes’ means the taxes described in section 2011(a).” Subsec. (b)(5). Pub. L. 107–16, § 532(c)(7)(C), substituted “2012 and 2013” for “2011 to 2013, inclusive,”. Subsec. (c). Pub. L. 107–16, § 532(c)(7)(B), redesignated subsec. (c) as (b). 1997—Subsec. (c)(3)(A). Pub. L. 105–34 substituted “the applicable credit amount in effect under section 2010(c) for the calendar year which includes the date of death” for “$192,800”. 1996—Subsec. (c)(3)(A). Pub. L. 104–188 inserted at end “For purposes of the preceding sentence, property shall not be treated as situated in the United States if such property is exempt from the tax imposed by this subchapter under any treaty obligation of the United States.” 1988—Subsec. (c)(1). Pub. L. 100–647, § 5032(b)(1)(A), substituted “$13,000” for “$3,600”. Subsec. (c)(2). Pub. L. 100–647, § 5032(b)(1), substituted “$13,000” for “$3,600” in subpar. (A) and “$46,800” for “$15,075” in subpar. (B). Subsec. (c)(3). Pub. L. 100–647, § 5032(b)(2), amended par. (3) generally, substituting provision relating to special rules for coordination with treaties and with gift tax unified tax credit for provision relating to a phase-in of the par. (2)(B) amount for decedents dying during 1977, 1978, 1979, and 1980. 1976—Subsec. (c). Pub. L. 94–455 added subsec. (c). 1966—Pub. L. 89–809 redesignated existing provisions as subsec. (a), inserted reference to special limitation provided in subsec. (b), and added subsec. (b).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 applicable to estates of decedents dying, and gifts made, after Dec. 31, 1997, see section 501(f) of Pub. L. 105–34, set out as a note under section 2001 of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 applicable to estates of decedents dying after Nov. 10, 1988, see section 5032(d) of Pub. L. 100–647, set out as a note under section 2101 of this title.
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as a note under section 2101 of this title.

legal/us/code/title-26/chapter-11/section-2103.md

@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2103"
+description: "Definition of gross estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2103"
+citation: "26 U.S.C. § 2103"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2103"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "56be2b809501e8c77cab071a9d5c53e9d1970eb3c1e21ef07af19342a020fc1f"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "f6baf16129bf9eaf91a86a8b76dae88f1cb9c34975909c430a5cd1209eb33680"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2103 - Definition of gross estate
+
+## Text
+
+For the purpose of the tax imposed by section 2101, the value of the gross estate of every decedent nonresident not a citizen of the United States shall be that part of his gross estate (determined as provided in section 2031) which at the time of his death is situated in the United States.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 397.)

legal/us/code/title-26/chapter-11/section-2104.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2104"
+description: "Property within the United States"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2104"
+citation: "26 U.S.C. § 2104"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2104"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "fcbac53b5abce9acc75e2a9cc2e403958d5654d18917f144e46cfaf1d498dd50"
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+text_hash: "ad6a80485b375dc047aa1f625ea59cc987f98ba1eb5e76390200f9537ad45c27"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2104 - Property within the United States
+
+## Text
+
+(a) Stock in corporation For purposes of this subchapter shares of stock owned and held by a nonresident not a citizen of the United States shall be deemed property within the United States only if issued by a domestic corporation.
+
+(b) Revocable transfers and transfers within 3 years of death For purposes of this subchapter, any property of which the decedent has made a transfer, by trust or otherwise, within the meaning of sections 2035 to 2038, inclusive, shall be deemed to be situated in the United States, if so situated either at the time of the transfer or at the time of the decedent’s death.
+
+(c) Debt obligations For purposes of this subchapter, debt obligations of—
+
+(1) a United States person, or
+
+(2) the United States, a State or any political subdivision thereof, or the District of Columbia,
+
+owned and held by a nonresident not a citizen of the United States shall be deemed property within the United States. Deposits with a domestic branch of a foreign corporation, if such branch is engaged in the commercial banking business, shall, for purposes of this subchapter, be deemed property within the United States. This subsection shall not apply to a debt obligation to which section 2105(b) applies.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 397; Pub. L. 89–809, title I, § 108(c), Nov. 13, 1966, 80 Stat. 1572; Pub. L. 91–172, title IV, § 435(b), Dec. 30, 1969, 83 Stat. 625; Pub. L. 93–17, § 3(a)(1), Apr. 10, 1973, 87 Stat. 12; Pub. L. 93–625, § 9(b), Jan. 3, 1975, 88 Stat. 2116; Pub. L. 94–455, title XX, § 2001(c)(1)(L), Oct. 4, 1976, 90 Stat. 1853; Pub. L. 100–647, title I, § 1012(q)(11), Nov. 10, 1988, 102 Stat. 3525; Pub. L. 104–188, title I, § 1704(t)(38), Aug. 20, 1996, 110 Stat. 1889; Pub. L. 111–226, title II, § 217(c)(3), Aug. 10, 2010, 124 Stat. 2402; Pub. L. 113–295, div. A, title II, § 221(a)(98), Dec. 19, 2014, 128 Stat. 4051.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2014—Subsec. (c). Pub. L. 113–295 substituted “Deposits” for “With respect to estates of decedents dying after December 31, 1969, deposits” in concluding provisions. 2010—Subsec. (c). Pub. L. 111–226, in concluding provisions, struck out before period at end “or to a debt obligation of a domestic corporation if any interest on such obligation, were such interest received by the decedent at the time of his death, would be treated by reason of section 861(a)(1)(A) as income from sources without the United States”. 1996—Subsec. (c). Pub. L. 104–188 substituted “section 861(a)(1)(A)” for “subparagraph (A), (C), or (D) of section 861(a)(1)” in concluding provisions. 1988—Subsec. (c). Pub. L. 100–647 substituted “subparagraph (A), (C), or (D) of section 861(a)(1)” for “section 861(a)(1)(B), section 861(a)(1)(G), or section 861(a)(1)(H)”. 1976—Subsec. (b). Pub. L. 94–455 substituted “and transfers within 3 years of death” for “and transfers in contemplation of death” after “Revocable transfers”. 1975—Subsec. (c). Pub. L. 93–625 inserted reference to section 861(a)(1)(H) of this title in last sentence. 1973—Subsec. (c). Pub. L. 93–17 made subsec. (c) inapplicable to debt obligations where interest on such obligations is treated as income from sources without the United States by reason of section 861(a)(1)(G) of this title. 1969—Subsec. (c). Pub. L. 91–172 substituted “December 31, 1969” for “December 31, 1972” in provisions deeming deposit with a domestic branch of a foreign corporation if such branch is engaged in the commercial banking business to be property within the United States. 1966—Subsec. (c). Pub. L. 89–809 added subsec. (c).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2014 AmendmentAmendment by Pub. L. 113–295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as a note under section 1 of this title.
+
+Effective Date of 2010 AmendmentAmendment by Pub. L. 111–226 applicable to taxable years beginning after Dec. 31, 2010, with certain exceptions, see section 217(d) of Pub. L. 111–226, set out as a note under section 861 of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 not applicable to transfers made before Jan. 1, 1977, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1975 AmendmentAmendment by Pub. L. 93–625 applicable with respect to estates of decedents dying after Jan. 3, 1975, see section 9(c) of Pub. L. 93–625, set out as a note under section 861 of this title.
+
+Effective Date of 1973 AmendmentPub. L. 93–17, § 3(a)(2), Apr. 10, 1973, 87 Stat. 12, provided that: “The amendment made by paragraph (1) [amending this section] shall apply with respect to estates of decedents dying after December 31, 1972, except that in the case of the assumption of a debt obligation of a foreign corporation which is treated as issued under section 4912(c)(2) after December 31, 1972, and before January 1, 1974, the amendment made by paragraph (1) [amending this section] shall apply with respect to estates of decedents dying after December 31, 1973.”
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as a note under section 2101 of this title.
+
+Short Title of 1973 AmendmentPub. L. 93–17, § 1(a), Apr. 10, 1973, 87 Stat. 12, provided that: “This Act [enacting sections 4922 and 6689 of this title, amending this section and sections 4911, 4912, 4914, 4915, 4916, 4918, 4919, 4920, and 6611 of this title, and enacting provisions set out as notes under this section] may be cited as the ‘Interest Equalization Tax Extension Act of 1973’.”

legal/us/code/title-26/chapter-11/section-2105.md

@@ -0,0 +1,91 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2105"
+description: "Property without the United States"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2105"
+citation: "26 U.S.C. § 2105"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2105"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "70d998f049a2642c70042fb5814d7e277c24356e43c578bf94dfdc88ec2e42f9"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "6edc90139a7d68332e231e0d9ec4c9e6ca2a0c1f3cd951fd0d74075a01c30e65"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2105 - Property without the United States
+
+## Text
+
+(a) Proceeds of life insurance For purposes of this subchapter, the amount receivable as insurance on the life of a nonresident not a citizen of the United States shall not be deemed property within the United States.
+
+(b) Bank deposits and certain other debt obligations For purposes of this subchapter, the following shall not be deemed property within the United States—
+
+(1) amounts described in section 871(i)(3), if any interest thereon would not be subject to tax by reason of section 871(i)(1) were such interest received by the decedent at the time of his death,
+
+(2) deposits with a foreign branch of a domestic corporation or domestic partnership, if such branch is engaged in the commercial banking business,
+
+(3) debt obligations, if, without regard to whether a statement meeting the requirements of section 871(h)(5) has been received, any interest thereon would be eligible for the exemption from tax under section 871(h)(1) were such interest received by the decedent at the time of his death, and
+
+(4) obligations which would be original issue discount obligations as defined in section 871(g)(1) but for subparagraph (B)(i) thereof, if any interest thereon (were such interest received by the decedent at the time of his death) would not be effectively connected with the conduct of a trade or business within the United States.
+
+Notwithstanding the preceding sentence, if any portion of the interest on an obligation referred to in paragraph (3) would not be eligible for the exemption referred to in paragraph (3) by reason of section 871(h)(4) if the interest were received by the decedent at the time of his death, then an appropriate portion (as determined in a manner prescribed by the Secretary) of the value (as determined for purposes of this chapter) of such debt obligation shall be deemed property within the United States.
+
+(c) Works of art on loan for exhibition For purposes of this subchapter, works of art owned by a nonresident not a citizen of the United States shall not be deemed property within the United States if such works of art are—
+
+(1) imported into the United States solely for exhibition purposes,
+
+(2) loaned for such purposes, to a public gallery or museum, no part of the net earnings of which inures to the benefit of any private stockholder or individual, and
+
+(3) at the time of the death of the owner, on exhibition, or en route to or from exhibition, in such a public gallery or museum.
+
+(d) Stock in a RIC (1) In general For purposes of this subchapter, stock in a regulated investment company (as defined in section 851) owned by a nonresident not a citizen of the United States shall not be deemed property within the United States in the proportion that, at the end of the quarter of such investment company’s taxable year immediately preceding a decedent’s date of death (or at such other time as the Secretary may designate in regulations), the assets of the investment company that were qualifying assets with respect to the decedent bore to the total assets of the investment company.
+
+(2) Qualifying assets For purposes of this subsection, qualifying assets with respect to a decedent are assets that, if owned directly by the decedent, would have been—
+
+(A) amounts, deposits, or debt obligations described in subsection (b) of this section,
+
+(B) debt obligations described in the last sentence of section 2104(c), or
+
+(C) other property not within the United States.
+
+(3) Termination This subsection shall not apply to estates of decedents dying after December 31, 2011.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 397; Pub. L. 89–809, title I, § 108(d), Nov. 13, 1966, 80 Stat. 1572; Pub. L. 98–369, div. A, title I, § 127(d), July 18, 1984, 98 Stat. 651; Pub. L. 100–647, title I, § 1012(g)(4), Nov. 10, 1988, 102 Stat. 3501; Pub. L. 103–66, title XIII, § 13237(b), Aug. 10, 1993, 107 Stat. 508; Pub. L. 105–34, title XIII, § 1304(a), Aug. 5, 1997, 111 Stat. 1040; Pub. L. 108–357, title IV, § 411(b), Oct. 22, 2004, 118 Stat. 1504; Pub. L. 110–343, div. C, title II, § 207(a), Oct. 3, 2008, 122 Stat. 3865; Pub. L. 111–312, title VII, § 726(a), Dec. 17, 2010, 124 Stat. 3316.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2010—Subsec. (d)(3). Pub. L. 111–312 substituted “December 31, 2011” for “December 31, 2009”. 2008—Subsec. (d)(3). Pub. L. 110–343 substituted “December 31, 2009” for “December 31, 2007”. 2004—Subsec. (d). Pub. L. 108–357 added subsec. (d). 1997—Subsec. (b)(4). Pub. L. 105–34 added par. (4). 1993—Subsec. (b). Pub. L. 103–66 substituted “this subchapter, the following shall not be deemed property within the United States” for “this subchapter” in introductory provisions, added par. (3) and concluding provisions, and struck out former par. (3) and concluding provisions which read as follows: “(3) debt obligations, if, without regard to whether a statement meeting the requirements of section 871(h)(4) has been received, any interest thereon would be eligible for the exemption from tax under section 871(h)(1) were such interest received by the decedent at the time of his death, shall not be deemed property within the United States.” 1988—Subsec. (b)(1). Pub. L. 100–647 substituted “section 871(i)(3), if any interest thereon would not be subject to tax by reason of section 871(i)(1)” for “section 861(c), if any interest thereon would be treated by reason of section 861(a)(1)(A) as income from sources without the United States”. 1984—Subsec. (b). Pub. L. 98–369, amended subsec. (b) generally, substituting “Bank deposits and certain other debt obligations” for “Certain bank deposits, etc.” in heading and “, if any interest thereon would be treated by reason of section 861(a)(1)(A) as income from sources without the United States were such interest received by the decedent at the time of his death,” for “if any interest thereon, were such interest received by the decedent at the time of his death, would be treated by reason of section 861(a)(1)(A) as income from sources without the United States, and” in par. (1), inserting “and” after “business,” in par. (2), and adding par. (3). 1966—Subsec. (b). Pub. L. 89–809 substituted amounts described in section 861(c) if any interest thereon, were such interest received by the decedent at the time of his death, would be treated by reason of section 861(a)(1)(A) as income from sources without the United States, and deposits with a foreign branch of a domestic corporation or domestic partnership, if such branch is engaged in the commercial banking business for moneys deposited with any person carrying on the banking business by or for a nonresident not a citizen of the United States who was not engaged in business in the United States at the time of his death as the property not to be deemed property within the United States for purposes of this subchapter.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2010 AmendmentPub. L. 111–312, title VII, § 726(b), Dec. 17, 2010, 124 Stat. 3317, provided that: “The amendment made by this section [amending this section] shall apply to estates of decedents dying after December 31, 2009.”
+
+Effective Date of 2008 AmendmentPub. L. 110–343, div. C, title II, § 207(b), Oct. 3, 2008, 122 Stat. 3865, provided that: “The amendment made by this section [amending this section] shall apply to decedents dying after December 31, 2007.”
+
+Effective Date of 2004 AmendmentAmendment by Pub. L. 108–357 applicable to estates of decedents dying after Dec. 31, 2004, see section 411(d)(2) of Pub. L. 108–357, set out as a note under section 871 of this title.
+
+Effective Date of 1997 AmendmentPub. L. 105–34, title XIII, § 1304(b), Aug. 5, 1997, 111 Stat. 1040, provided that: “The amendment made by this section [amending this section] shall apply to estates of decedents dying after the date of the enactment of this Act [Aug. 5, 1997].”
+
+Effective Date of 1993 AmendmentAmendment by Pub. L. 103–66 applicable to the estates of decedents dying after Dec. 31, 1993, see section 13237(d) of Pub. L. 103–66, set out as a note under section 871 of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
+
+Effective Date of 1984 AmendmentAmendment by Pub. L. 98–369 applicable to obligations issued after July 18, 1984, with respect to the estates of decedents dying after such date, see section 127(g)(2) of Pub. L. 98–369, set out as a note under section 871 of this title.
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as a note under section 2101 of this title.

legal/us/code/title-26/chapter-11/section-2106.md

@@ -0,0 +1,97 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2106"
+description: "Taxable estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2106"
+citation: "26 U.S.C. § 2106"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2106"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "e48ffa9af81fa5ecded028d7c80c5e18158f2d368cfa5f26aeb8f44f81e5a3fb"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "e25f1169bc9c551f31db8e505ac6c70c80292bdb07c7b3dc9c7ae702c57ca43f"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2106 - Taxable estate
+
+## Text
+
+(a) Definition of taxable estate For purposes of the tax imposed by section 2101, the value of the taxable estate of every decedent nonresident not a citizen of the United States shall be determined by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States—
+
+(1) Expenses, losses, indebtedness, and taxes That proportion of the deductions specified in sections 2053 and 2054 (other than the deductions described in the following sentence) which the value of such part bears to the value of his entire gross estate, wherever situated. Any deduction allowable under section 2053 in the case of a claim against the estate which was founded on a promise or agreement but was not contracted for an adequate and full consideration in money or money’s worth shall be allowable under this paragraph to the extent that it would be allowable as a deduction under paragraph (2) if such promise or agreement constituted a bequest.
+
+(2) Transfers for public, charitable, and religious uses (A) In general The amount of all bequests, legacies, devises, or transfers (including the interest which falls into any such bequest, legacy, devise, or transfer as a result of an irrevocable disclaimer of a bequest, legacy, devise, transfer, or power, if the disclaimer is made before the date prescribed for the filing of the estate tax return)—
+
+(i) to or for the use of the United States, any State, any political subdivision thereof, or the District of Columbia, for exclusively public purposes;
+
+(ii) to or for the use of any domestic corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, including the encouragement of art and the prevention of cruelty to children or animals, no part of the net earnings of which inures to the benefit of any private stockholder or individual, which is not disqualified for tax exemption under section 501(c)(3) by reason of attempting to influence legislation, and which does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office; or
+
+(iii) to a trustee or trustees, or a fraternal society, order, or association operating under the lodge system, but only if such contributions or gifts are to be used within the United States by such trustee or trustees, or by such fraternal society, order, or association, exclusively for religious, charitable, scientific, literary, or educational purposes, or for the prevention of cruelty to children or animals, such trust, fraternal society, order, or association would not be disqualified for tax exemption under section 501(c)(3) by reason of attempting to influence legislation, and such trustee or trustees, or such fraternal society, order, or association, does not participate in, or intervene in (including the publishing or distributing of statements), any political campaign on behalf of (or in opposition to) any candidate for public office;
+
+(B) Powers of appointment Property includible in the decedent’s gross estate under section 2041 (relating to powers of appointment) received by a donee described in this paragraph shall, for purposes of this paragraph, be considered a bequest of such decedent.
+
+(C) Death taxes payable out of bequests If the tax imposed by section 2101, or any estate, succession, legacy, or inheritance taxes, are, either by the terms of the will, by the law of the jurisdiction under which the estate is administered, or by the law of the jurisdiction imposing the particular tax, payable in whole or in part out of the bequests, legacies, or devises otherwise deductible under this paragraph, then the amount deductible under this paragraph shall be the amount of such bequests, legacies, or devises reduced by the amount of such taxes.
+
+(D) Limitation on deduction The amount of the deduction under this paragraph for any transfer shall not exceed the value of the transferred property required to be included in the gross estate.
+
+(E) Disallowance of deductions in certain cases The provisions of section 2055(e) shall be applied in the determination of the amount allowable as a deduction under this paragraph.
+
+(F) Cross references (i) For option as to time for valuation for purposes of deduction under this section, see section 2032.
+
+(ii) For exemption of certain bequests for the benefit of the United States and for rules of construction for certain bequests, see section 2055(g).
+
+(iii) For treatment of gifts and bequests to or for the use of Indian tribal governments (or their subdivisions), see section 7871.
+
+(3) Marital deduction The amount which would be deductible with respect to property situated in the United States at the time of the decedent’s death under the principles of section 2056.
+
+(4) State death taxes The amount which bears the same ratio to the State death taxes as the value of the property, as determined for purposes of this chapter, upon which State death taxes were paid and which is included in the gross estate under section 2103 bears to the value of the total gross estate under section 2103. For purposes of this paragraph, the term “State death taxes” means the taxes described in section 2058(a).
+
+(b) Condition of allowance of deductions No deduction shall be allowed under paragraphs (1) and (2) of subsection (a) in the case of a nonresident not a citizen of the United States unless the executor includes in the return required to be filed under section 6018 the value at the time of his death of that part of the gross estate of such nonresident not situated in the United States.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 398; Pub. L. 85–866, title I, § 30(d), Sept. 2, 1958, 72 Stat. 1631; Pub. L. 86–779, § 4(c), Sept. 14, 1960, 74 Stat. 1000; Pub. L. 89–809, title I, § 108(e), Nov. 13, 1966, 80 Stat. 1572; Pub. L. 91–172, title II, § 201(d)(2), (4)(B), Dec. 30, 1969, 83 Stat. 561; Pub. L. 94–455, title XIII, § 1307(d)(1)(B)(iii), (C), title XIX, § 1902(a)(5), (12)(A), title XX, § 2001(c)(1)(F), Oct. 4, 1976, 90 Stat. 1727, 1805, 1852; Pub. L. 97–473, title II, § 202(b)(6), Jan. 14, 1983, 96 Stat. 2610; Pub. L. 99–514, title XIV, § 1422(c), Oct. 22, 1986, 100 Stat. 2717; Pub. L. 100–203, title X, § 10711(a)(4), Dec. 22, 1987, 101 Stat. 1330–464; Pub. L. 100–647, title V, § 5033(c), Nov. 10, 1988, 102 Stat. 3672; Pub. L. 101–239, title VII, § 7815(d)(3), Dec. 19, 1989, 103 Stat. 2415; Pub. L. 107–16, title V, § 532(c)(8), June 7, 2001, 115 Stat. 75; Pub. L. 113–295, div. A, title II, § 221(a)(95)(A)(ii), Dec. 19, 2014, 128 Stat. 4051; Pub. L. 115–141, div. U, title IV, § 401(a)(203), Mar. 23, 2018, 132 Stat. 1194.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2018—Subsec. (a)(4). Pub. L. 115–141 inserted “section” before “2058(a).” 2014—Subsec. (a)(4). Pub. L. 113–295 substituted “2058(a)” for “section 2011(a)”. 2001—Subsec. (a)(4). Pub. L. 107–16 added par. (4). 1989—Subsec. (a)(3). Pub. L. 101–239 struck out “allowed where spouse is citizen” after “deduction” in heading. 1988—Subsec. (a)(3). Pub. L. 100–647 added par. (3). 1987—Subsec. (a)(2)(A)(ii), (iii). Pub. L. 100–203 inserted “(or in opposition to)” after “on behalf of”. 1986—Subsec. (a)(2)(F)(ii). Pub. L. 99–514 substituted “section 2055(g)” for “section 2055(f)”. 1983—Subsec. (a)(2)(F). Pub. L. 97–473 substituted “(i)” and “(ii)” for “(1)” and “(2)”, respectively, and added cl. (iii). 1976—Subsec. (a)(2)(A)(i). Pub. L. 94–455, § 1902(a)(12)(A), struck out “Territory” after “any State”. Subsec. (a)(2)(A)(ii). Pub. L. 94–455, § 1307(d)(1)(B)(iii), substituted “which is not disqualified for tax exemption under section 501(c)(3) by reason of attempting to influence legislation” for “no substantial part of the activities of which is carrying on propaganda, or otherwise attempting, to influence legislation” after “stockholder or individual”. Subsec. (a)(2)(A)(iii). Pub. L. 94–455, § 1307(d)(1)(C), substituted “such trust, fraternal society, order, or association would not be disqualified for tax exemption under section 501(c)(3) by reason of attempting to influence legislation” for “no substantial part of the activities of such trustee or trustees, or of such fraternal society, order, or association, is carrying on propaganda, or otherwise attempting, to influence legislation” after “children or animals”. Subsec. (a)(2)(F). Pub. L. 94–455, § 1902(a)(5)(A), substituted “Cross references” for “Other cross references” after “(F)”, in cl. (1) “purposes of deduction under this section” for “purpose of deduction under this paragraph” after “valuation for”, in cl. (2) provision for exemption of certain bequests for benefit of United States and for rules of construction for certain bequests, for provisions of cls. (2) to (11) relating to bequests to; Library of Congress, Post Office Department, Office of Naval Records and Library, National Park Service, Department of State, Department of Justice, payment of tax on bequests of United States obligations, Naval Academy, Naval Academy Museum, and National Archives Trust Fund Board, respectively. Subsec. (a)(3). Pub. L. 94–455, § 2001(c)(1)(F), struck out par. (3) relating to specific exemption in case of decedents nonresidents not citizens. Subsec. (c). Pub. L. 94–455, § 1902(a)(5)(B), struck out subsec. (c) relating to treatment of United States bonds in determining gross estate of a decedent who was not engaged in business in the United States at the time of his death. 1969—Subsec. (a)(2)(A)(ii), (iii). Pub. L. 91–172, § 201(d)(4)(B), inserted non-participation and non-intervention in political campaigns as an additional qualification. Subsec. (a)(2)(E). Pub. L. 91–172, § 201(d)(2), substituted substantive provisions for simple reference to sections 503 and 681 of this title in which such substantive provisions were formerly set out. 1966—Subsec. (a)(3). Pub. L. 89–809 substituted “$30,000” for “$2,000” as size of exemption in subpar. (A) and “$30,000” for “$2,000” as item (i) in formula set out in subpar. (B). 1960—Subsec. (a)(3). Pub. L. 86–779 designated existing provisions as subpar. (A) and added subpar. (B). 1958—Subsec. (a)(2)(E). Pub. L. 85–866 substituted “503” for “504”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2014 AmendmentAmendment by Pub. L. 113–295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as a note under section 1 of this title.
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1989 AmendmentAmendment by Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
+
+Effective Date of 1988 AmendmentAmendment by Pub. L. 100–647 applicable to estates of decedents dying after Nov. 10, 1988, see section 5033(d)(1) of Pub. L. 100–647, set out as a note under section 2056 of this title.
+
+Effective Date of 1987 AmendmentAmendment by Pub. L. 100–203 applicable with respect to activities after Dec. 22, 1987, see section 10711(c) of Pub. L. 100–203, set out as a note under section 170 of this title.
+
+Effective Date of 1986 AmendmentAmendment by Pub. L. 99–514 applicable to transfers and contributions made after Dec. 31, 1986, see section 1422(e) of Pub. L. 99–514, set out as a note under section 2055 of this title.
+
+Effective Date of 1983 AmendmentFor effective date of amendment by Pub. L. 97–473, see section 204(3) of Pub. L. 97–473, set out as an Effective Date note under section 7871 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(5), (12)(A) of Pub. L. 94–455 applicable in the case of estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title. Amendment by section 2001(c)(1)(F) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective Date of 1969 AmendmentAmendment by section 201(d)(2) of Pub. L. 91–172 applicable in the case of decedents dying after Dec. 31, 1969, with specified exceptions, see section 201(g)(4) of Pub. L. 91–172, set out as a note under section 170 of this title. Amendment by section 201(d)(4)(B) of Pub. L. 91–172 applicable to gifts and transfers made after Dec. 31, 1969, see section 201(g)(4) of Pub. L. 91–172, set out as a note under section 170 of this title.
+
+Effective Date of 1966 AmendmentAmendment by Pub. L. 89–809 applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as a note under section 2101 of this title.
+
+Effective Date of 1960 AmendmentPub. L. 86–779, § 4(e)(2), Sept. 14, 1960, 74 Stat. 1000, provided that: “The amendments made by subsections (b) and (c) [enacting section 2209 of this title and amending this section] shall apply with respect to estates of decedents dying after the date of the enactment of this Act [Sept. 14, 1960].”
+
+Application of Amendments by Section 5033 of Pub. L. 100–647 to Estates of, or Gifts by, Noncitizen and Nonresident IndividualsFor provisions directing that in the case of the estate of, or gift by, an individual who was not a citizen or resident of the United States but was a resident of a foreign country with which the United States has a tax treaty with respect to estate, inheritance, or gift taxes, the amendments made by section 5033 of Pub. L. 100–647 shall not apply to the extent such amendments would be inconsistent with the provisions of such treaty relating to estate, inheritance, or gift tax marital deductions, but that in the case of the estate of an individual dying before the date 3 years after Dec. 19, 1989, or a gift by an individual before the date 3 years after Dec. 19, 1989, the requirement of the preceding provision that the individual not be a citizen or resident of the United States shall not apply, see section 7815(d)(14) of Pub. L. 101–239, set out as a note under section 2056 of this title.

legal/us/code/title-26/chapter-11/section-2107.md

@@ -0,0 +1,91 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2107"
+description: "Expatriation to avoid tax"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2107"
+citation: "26 U.S.C. § 2107"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2107"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "b33493cefda8bdfd12db3a6be76c41828e72fc72ed6f17ef856270e0d32b83a7"
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+text_hash: "199901c64f8200ea0902f47b577d3466eee2e1f386c30452049e7f1254100b42"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2107 - Expatriation to avoid tax
+
+## Text
+
+(a) Treatment of expatriates A tax computed in accordance with the table contained in section 2001 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 if the date of death occurs during a taxable year with respect to which the decedent is subject to tax under section 877(b).
+
+(b) Gross estate For purposes of the tax imposed by subsection (a), the value of the gross estate of every decedent to whom subsection (a) applies shall be determined as provided in section 2103, except that—
+
+(1) if such decedent owned (within the meaning of section 958(a)) at the time of his death 10 percent or more of the total combined voting power of all classes of stock entitled to vote of a foreign corporation, and
+
+(2) if such decedent owned (within the meaning of section 958(a)), or is considered to have owned (by applying the ownership rules of section 958(b)), at the time of his death, more than 50 percent of—
+
+(A) the total combined voting power of all classes of stock entitled to vote of such corporation, or
+
+(B) the total value of the stock of such corporation,
+
+then that proportion of the fair market value of the stock of such foreign corporation owned (within the meaning of section 958(a)) by such decedent at the time of his death, which the fair market value of any assets owned by such foreign corporation and situated in the United States, at the time of his death, bears to the total fair market value of all assets owned by such foreign corporation at the time of his death, shall be included in the gross estate of such decedent. For purposes of the preceding sentence, a decedent shall be treated as owning stock of a foreign corporation at the time of his death if, at the time of a transfer, by trust or otherwise, within the meaning of sections 2035 to 2038, inclusive, he owned such stock.
+
+(c) Credits (1) Unified credit (A) In general A credit of $13,000 shall be allowed against the tax imposed by subsection (a).
+
+(B) Limitation based on amount of tax The credit allowed under this paragraph shall not exceed the amount of the tax imposed by subsection (a).
+
+(2) Credit for foreign death taxes (A) In general The tax imposed by subsection (a) shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any foreign country in respect of any property which is included in the gross estate solely by reason of subsection (b).
+
+(B) Limitation on credit The credit allowed by subparagraph (A) for such taxes paid to a foreign country shall not exceed the lesser of—
+
+(i) the amount which bears the same ratio to the amount of such taxes actually paid to such foreign country as the value of the property subjected to such taxes by such foreign country and included in the gross estate solely by reason of subsection (b) bears to the value of all property subjected to such taxes by such foreign country, or
+
+(ii) such property’s proportionate share of the excess of—
+
+(I) the tax imposed by subsection (a), over
+
+(II) the tax which would be imposed by section 2101 but for this section.
+
+(C) Proportionate share In the case of property which is included in the gross estate solely by reason of subsection (b), such property’s proportionate share is the percentage which the value of such property bears to the total value of all property included in the gross estate solely by reason of subsection (b).
+
+(3) Other credits The tax imposed by subsection (a) shall be credited with the amounts determined in accordance with subsections (a) and (b) of section 2102. For purposes of subsection (a) of section 2102, sections 2012 and 2013 shall be applied as if the credit allowed under paragraph (1) were allowed under section 2010.
+
+(d) Burden of proof If the Secretary establishes that it is reasonable to believe that an individual’s loss of United States citizenship would, but for this section, result in a substantial reduction in the estate, inheritance, legacy, and succession taxes in respect of the transfer of his estate, the burden of proving that such loss of citizenship did not have for one of its principal purposes the avoidance of taxes under this subtitle or subtitle A shall be on the executor of such individual’s estate.
+
+(e) Cross reference For comparable treatment of long-term lawful permanent residents who ceased to be taxed as residents, see section 877(e).
+
+(Added Pub. L. 89–809, title I, § 108(f), Nov. 13, 1966, 80 Stat. 1573; amended Pub. L. 94–455, title XIX, §§ 1902(a)(6), 1906(b)(13)(A), title XX, § 2001(c)(1)(E)(ii), Oct. 4, 1976, 90 Stat. 1805, 1834, 1851; Pub. L. 104–191, title V, § 511(e)(1), (f)(2)(A), Aug. 21, 1996, 110 Stat. 2097, 2099; Pub. L. 105–34, title XVI, § 1602(g)(6), Aug. 5, 1997, 111 Stat. 1095; Pub. L. 107–16, title V, § 532(c)(7)(C), June 7, 2001, 115 Stat. 75; Pub. L. 108–357, title VIII, § 804(a)(3), Oct. 22, 2004, 118 Stat. 1570.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2004—Subsec. (a). Pub. L. 108–357 reenacted heading without change and amended text of subsec. (a) generally, substituting provisions relating to imposition of tax on the transfer of the taxable estate of every decedent nonresident not a citizen of the United States if the date of death occurs during a taxable year with respect to which the decedent is subject to tax under section 877(b), for provisions relating to imposition of tax on the transfer of the taxable estate of every decedent nonresident not a citizen of the United States if, within the 10-year period ending with the date of death, such decedent lost United States citizenship, unless such loss did not have for one of its principal purposes the avoidance of taxes, and provisions describing individuals to be treated as having a principal purpose to avoid taxes. 2001—Subsec. (c)(3). Pub. L. 107–16 substituted “2012 and 2013” for “2011 to 2013, inclusive,”. 1997—Subsec. (c)(2)(B)(i). Pub. L. 105–34, § 1602(g)(6)(A), substituted “such foreign country as the value of the property subjected to such taxes by such foreign country and” for “such foreign country in respect of property included in the gross estate as the value of the property”. Subsec. (c)(2)(C). Pub. L. 105–34, § 1602(g)(6)(B), amended heading and text of subpar. (C) generally. Prior to amendment, text read as follows: “For purposes of subparagraph (B), a property’s proportionate share is the percentage of the value of the property which is included in the gross estate solely by reason of subsection (b) bears to the total value of the gross estate.” 1996—Subsec. (a). Pub. L. 104–191, § 511(e)(1)(A), substituted “Treatment of expatriates” for “Rate of tax” in heading and amended text generally. Prior to amendment, text read as follows: “A tax computed in accordance with the table contained in section 2001 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 dying after November 13, 1966, if after March 8, 1965, and within the 10-year period ending with the date of death such decedent lost United States citizenship, unless such loss did not have for one of its principal purposes the avoidance of taxes under this subtitle or subtitle A.” Subsec. (b)(2). Pub. L. 104–191, § 511(e)(1)(C), substituted “more than 50 percent of—” for “more than 50 percent of the total combined voting power of all classes of stock entitled to vote of such foreign corporation,” and added subpars. (A) and (B). Subsec. (c)(2), (3). Pub. L. 104–191, § 511(e)(1)(B), added par. (2) and redesignated former par. (2) as (3). Subsec. (d). Pub. L. 104–191, § 511(f)(2)(A), redesignated subsec. (e) as (d) and struck out former subsec. (d) which read as follows: “(d) Exception for Loss of Citizenship for Certain Causes.—Subsection (a) shall not apply to the transfer of the estate of a decedent whose loss of United States citizenship resulted from the application of section 301(b), 350, or 355 of the Immigration and Nationality Act, as amended (8 U.S.C. 1401(b), 1482, or 1487).” Subsec. (e). Pub. L. 104–191, § 511(f)(2)(A), added subsec. (e). Former subsec. (e) redesignated (d). 1976—Subsec. (a). Pub. L. 94–455, § 1902(a)(6), substituted “November 13, 1966” for “the date of enactment of this section” after “dying after”. Subsec. (c). Pub. L. 94–455, § 2001(c)(1)(E)(ii), substituted provisions relating to unified credit for “The tax imposed by subsection (a) shall be credited with the amounts determined in accordance with section 2102.” Subsec. (e). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2004 AmendmentAmendment by Pub. L. 108–357 applicable to individuals who expatriate after June 3, 2004, see section 804(f) of Pub. L. 108–357, set out as a note under section 877 of this title.
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 effective as if included in the provisions of the Health Insurance Portability and Accountability Act of 1996, Pub. L. 104–191, to which such amendment relates, see section 1602(i) of Pub. L. 105–34, set out as a note under section 26 of this title.
+
+Effective Date of 1996 AmendmentAmendment by Pub. L. 104–191 applicable to individuals losing United States citizenship on or after Feb. 6, 1995, and to long-term residents of the United States with respect to whom an event described in section 877(e)(1)(A) or (B) of this title occurs on or after Feb. 6, 1995, with special rule for certain individuals who performed an act of expatriation specified in section 1481(a)(1)–(4) of Title 8, Aliens and Nationality, before Feb. 6, 1995, see section 511(g) of Pub. L. 104–191, set out as a note under section 877 of this title.
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(6) of Pub. L. 94–455 applicable in the case of estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title. Amendment by section 2001(c)(1)(E)(ii) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.
+
+Effective DateSection applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as an Effective Date of 1966 Amendment note under section 2101 of this title.

legal/us/code/title-26/chapter-11/section-2108.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2108"
+description: "Application of pre-1967 estate tax provisions"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2108"
+citation: "26 U.S.C. § 2108"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2108"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "2532f8c879ef7b376540e2ca741d5b9640a4b2cbf3e0e7e9d234ffd992563ebf"
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+text_hash: "a25078e3c999b645f7547d6a7578d2041f9c6301ee171b0bbc39d0df12c81b66"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2108 - Application of pre-1967 estate tax provisions
+
+## Text
+
+(a) Imposition of more burdensome tax by foreign country Whenever the President finds that—
+
+(1) under the laws of any foreign country, considering the tax system of such foreign country, a more burdensome tax is imposed by such foreign country on the transfer of estates of decedents who were citizens of the United States and not residents of such foreign country than the tax imposed by this subchapter on the transfer of estates of decedents who were residents of such foreign country,
+
+(2) such foreign country, when requested by the United States to do so, has not acted to revise or reduce such tax so that it is no more burdensome than the tax imposed by this subchapter on the transfer of estates of decedents who were residents of such foreign country, and
+
+(3) it is in the public interest to apply pre-1967 tax provisions in accordance with this section to the transfer of estates of decedents who were residents of such foreign country,
+
+the President shall proclaim that the tax on the transfer of the estate of every decedent who was a resident of such foreign country at the time of his death shall, in the case of decedents dying after the date of such proclamation, be determined under this subchapter without regard to amendments made to sections 2101 (relating to tax imposed), 2102 (relating to credits against tax), 2106 (relating to taxable estate), and 6018 (relating to estate tax returns) on or after November 13, 1966.
+
+(b) Alleviation of more burdensome tax Whenever the President finds that the laws of any foreign country with respect to which the President has made a proclamation under subsection (a) have been modified so that the tax on the transfer of estates of decedents who were citizens of the United States and not residents of such foreign country is no longer more burdensome than the tax imposed by this subchapter on the transfer of estates of decedents who were residents of such foreign country, he shall proclaim that the tax on the transfer of the estate of every decedent who was a resident of such foreign country at the time of his death shall, in the case of decedents dying after the date of such proclamation, be determined under this subchapter without regard to subsection (a).
+
+(c) Notification of Congress required No proclamation shall be issued by the President pursuant to this section unless, at least 30 days prior to such proclamation, he has notified the Senate and the House of Representatives of his intention to issue such proclamation.
+
+(d) Implementation by regulations The Secretary shall prescribe such regulations as may be necessary or appropriate to implement this section.
+
+(Added Pub. L. 89–809, title I, § 108(f), Nov. 13, 1966, 80 Stat. 1573; amended Pub. L. 94–455, title XIX, §§ 1902(a)(6), 1906(b)(13)(A), Oct. 4, 1976, 90 Stat. 1805, 1834.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Subsec. (a). Pub. L. 94–455, § 1902(a)(6), substituted “November 13, 1976” for “the date of enactment of this section” after “on or after”. Subsec. (d). Pub. L. 94–455, § 1906(b)(13)(A), struck out “or his delegate” after “Secretary”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(6) of Pub. L. 94–455 applicable in the case of estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title.
+
+Effective DateSection applicable with respect to estates of decedents dying after Nov. 13, 1966, see section 108(i) of Pub. L. 89–809, set out as an Effective Date of 1966 Amendment note under section 2101 of this title.

legal/us/code/title-26/chapter-11/section-2201.md

@@ -0,0 +1,69 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2201"
+description: "Combat zone-related deaths of members of the Armed Forces, deaths of astronauts, and deaths of victims of certain terrorist attacks"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2201"
+citation: "26 U.S.C. § 2201"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2201"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "95535b772c8615fe27bb2a483c5cee2805add1185375420b988aa861554a4980"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "04ccfb6e6513dc543ba2c07ebbb4153456aef8c7c8d366d4b23b17970cb50eb8"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2201 - Combat zone-related deaths of members of the Armed Forces, deaths of astronauts, and deaths of victims of certain terrorist attacks
+
+## Text
+
+(a) In general Unless the executor elects not to have this section apply, in applying sections 2001 and 2101 to the estate of a qualified decedent, the rate schedule set forth in subsection (c) shall be deemed to be the rate schedule set forth in section 2001(c).
+
+(b) Qualified decedent For purposes of this section, the term “qualified decedent” means—
+
+(1) any citizen or resident of the United States dying while in active service of the Armed Forces of the United States, if such decedent—
+
+(A) was killed in action while serving in a combat zone, as determined under section 112(c), or
+
+(B) died as a result of wounds, disease, or injury suffered while serving in a combat zone (as determined under section 112(c)), and while in the line of duty, by reason of a hazard to which such decedent was subjected as an incident of such service,
+
+(2) any specified terrorist victim (as defined in section 692(d)(4)), and
+
+(3) any astronaut whose death occurs in the line of duty.
+
+(c) Rate schedule If the amount with respect to which the tentative tax to be computed is:The tentative tax is: Not over $150,0001 percent of the amount by which such amount exceeds $100,000. Over $150,000 but not over $200,000$500 plus 2 percent of the excess over $150,000. Over $200,000 but not over $300,000$1,500 plus 3 percent of the excess over $200,000. Over $300,000 but not over $500,000$4,500 plus 4 percent of the excess over $300,000. Over $500,000 but not over $700,000$12,500 plus 5 percent of the excess over $500,000. Over $700,000 but not over $900,000$22,500 plus 6 percent of the excess over $700,000. Over $900,000 but not over $1,100,000$34,500 plus 7 percent of the excess over $900,000. Over $1,100,000 but not over $1,600,000$48,500 plus 8 percent of the excess over $1,100,000. Over $1,600,000 but not over $2,100,000$88,500 plus 9 percent of the excess over $1,600,000. Over $2,100,000 but not over $2,600,000$133,500 plus 10 percent of the excess over $2,100,000. Over $2,600,000 but not over $3,100,000$183,500 plus 11 percent of the excess over $2,600,000. Over $3,100,000 but not over $3,600,000$238,500 plus 12 percent of the excess over $3,100,000. Over $3,600,000 but not over $4,100,000$298,500 plus 13 percent of the excess over $3,600,000. Over $4,100,000 but not over $5,100,000$363,500 plus 14 percent of the excess over $4,100,000. Over $5,100,000 but not over $6,100,000$503,500 plus 15 percent of the excess over $5,100,000. Over $6,100,000 but not over $7,100,000$653,500 plus 16 percent of the excess over $6,100,000. Over $7,100,000 but not over $8,100,000$813,500 plus 17 percent of the excess over $7,100,000. Over $8,100,000 but not over $9,100,000$983,500 plus 18 percent of the excess over $8,100,000. Over $9,100,000 but not over $10,100,000$1,163,500 plus 19 percent of the excess over $9,100,000. Over $10,100,000$1,353,500 plus 20 percent of the excess over $10,100,000.
+
+(d) Determination of unified credit In the case of an estate to which this section applies, subsection (a) shall not apply in determining the credit under section 2010.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 401; Pub. L. 93–597, § 6(b)(1), (2), Jan. 2, 1975, 88 Stat. 1953; Pub. L. 94–455, title XIX, § 1902(a)(7)(A), Oct. 4, 1976, 90 Stat. 1805; Pub. L. 107–16, title V, § 532(c)(9), June 7, 2001, 115 Stat. 75; Pub. L. 107–134, title I, § 103(a), (b)(3), Jan. 23, 2002, 115 Stat. 2430, 2431; Pub. L. 108–121, title I, § 110(c)(1), (2)(A), Nov. 11, 2003, 117 Stat. 1342.)
+
+## Notes
+
+Editorial Notes
+
+Amendments2003—Pub. L. 108–121, § 110(c)(2)(A), inserted “, deaths of astronauts,” after “Forces” in section catchline. Subsec. (b)(3). Pub. L. 108–121, § 110(c)(1), added par. (3). 2002—Pub. L. 107–134 amended section catchline and text of section generally, substituting present provisions for provisions which had stated that the additional estate tax as defined in former section 2011(d) should not apply to the transfer of the taxable estate of a citizen or resident of the United States dying while in active service as a member of the Armed Forces of the United States, if such decedent was killed in action while serving in a combat zone, as determined under section 112(c), or died as a result of wounds, disease, or injury suffered, while serving in a combat zone (as determined under section 112(c)), and while in line of duty, by reason of a hazard to which he was subjected as an incident of such service. 2001—Pub. L. 107–16, § 532(c)(9)(B), which added concluding provisions which read as follows: “For purposes of this section, the additional estate tax is the difference between the tax imposed by section 2001 or 2101 and the amount equal to 125 percent of the maximum credit provided by section 2011(b), as in effect before its repeal by the Economic Growth and Tax Relief Reconciliation Act of 2001.”, was repealed by Pub. L. 107–134, § 103(b)(3). See Effective Date of 2002 Amendment note below. Pub. L. 107–16, § 532(c)(9)(A), which struck out “as defined in section 2011(d)” after “The additional estate tax” in introductory provisions, was repealed by Pub. L. 107–134, § 103(b)(3). See Effective Date of 2002 Amendment note below. 1975—Pub. L. 93–597, as amended by Pub. L. 94–455, § 1902(a)(7)(A), struck out “during an induction period (as defined in section 112(c)(5))” after “resident of the United States dying”, and substituted “Members of the Armed Forces dying in combat zone or by reason of combat-zone-incurred wounds, etc.” for “Members of the Armed Forces dying during an induction period” in section catchline.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 2003 AmendmentPub. L. 108–121, title I, § 110(c)(3), Nov. 11, 2003, 117 Stat. 1343, provided that: “The amendments made by this subsection [amending this section] shall apply to estates of decedents dying after December 31, 2002.”
+
+Effective Date of 2002 AmendmentAmendment by Pub. L. 107–134 applicable to estates of decedents dying on or after Sept. 11, 2001, and, in the case of individuals dying as a result of the Apr. 19, 1995, terrorist attack, dying on or after Apr. 19, 1995, with provisions relating to waiver of limitations, see section 103(d) of Pub. L. 107–134, set out as a note under section 2053 of this title.
+
+Effective Date of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
+
+Effective Date of 1976 AmendmentPub. L. 94–455, title XIX, § 1902(a)(7)(B), Oct. 4, 1976, 90 Stat. 1805, provided that: “The amendment made by subsection (A) [amending section 6(b)(1) of Pub. L. 93–597] is effective July 1, 1973.”
+
+Effective Date of 1975 AmendmentPub. L. 93–597, § 6(c), Jan. 2, 1975, 88 Stat. 1953, provided that: “The amendments made by this section [amending this section and section 1034 of this title] shall take effect on July 1, 1973.”

legal/us/code/title-26/chapter-11/section-2202.md

@@ -0,0 +1,37 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2202"
+description: "Repealed. Pub. L. 94–455, title XIX, § 1902(a)(8), Oct. 4, 1976, 90 Stat. 1805]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2202"
+citation: "26 U.S.C. § 2202"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2202"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "03dc98cab83c3705eacf85691d6c5e0c6227f1c1f496bb7705a7bad33256465a"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "5d08d0ce5b2de3cf8b09c7911628517ca6a23d5a1a970a134ea3764cd9fd9256"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2202 - Repealed. Pub. L. 94–455, title XIX, § 1902(a)(8), Oct. 4, 1976, 90 Stat. 1805]
+
+## Notes
+
+Section, acts Aug. 16, 1954, ch. 736, 68A Stat. 401; June 25, 1959, Pub. L. 86–70, § 22(a), 73 Stat. 146; July 12, 1960, Pub. L. 86–624, § 18(b), 74 Stat. 416, related to the presumption that missionaries duly commissioned and serving under boards of foreign missions are residents of the State or the District of Columbia wherein they resided at the time of their commission and departure for service.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal applicable to estates of decedents dying after Oct. 4, 1976, see section 1902(c)(1) of Pub. L. 94–455, set out as an Effective Date of 1976 Amendment note under section 2012 of this title.

legal/us/code/title-26/chapter-11/section-2203.md

@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2203"
+description: "Definition of executor"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2203"
+citation: "26 U.S.C. § 2203"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2203"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
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+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "8e17c9ffae074df7931c81bae540f8fdb0c8954ea6022fa4beb38444258bc39e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2203 - Definition of executor
+
+## Text
+
+The term “executor” wherever it is used in this title in connection with the estate tax imposed by this chapter means the executor or administrator of the decedent, or, if there is no executor or administrator appointed, qualified, and acting within the United States, then any person in actual or constructive possession of any property of the decedent.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 401.)

legal/us/code/title-26/chapter-11/section-2204.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2204"
+description: "Discharge of fiduciary from personal liability"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2204"
+citation: "26 U.S.C. § 2204"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2204"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "9234072b0a9a1f47ec101eaa352701ad17a5bbe79e04ccf9eca633408d726167"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "3ad1f76b0c666c9f9518f789faa23c67779182be6d9019cc474fb43bcd190f95"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2204 - Discharge of fiduciary from personal liability
+
+## Text
+
+(a) General rule If the executor makes written application to the Secretary for determination of the amount of the tax and discharge from personal liability therefor, the Secretary (as soon as possible, and in any event within 9 months after the making of such application, or, if the application is made before the return is filed, then within 9 months after the return is filed, but not after the expiration of the period prescribed for the assessment of the tax in section 6501) shall notify the executor of the amount of the tax. The executor, on payment of the amount of which he is notified (other than any amount the time for payment of which is extended under sections 6161, 6163, or 6166), and on furnishing any bond which may be required for any amount for which the time for payment is extended, shall be discharged from personal liability for any deficiency in tax thereafter found to be due and shall be entitled to a receipt or writing showing such discharge.
+
+(b) Fiduciary other than the executor If a fiduciary (not including a fiduciary in respect of the estate of a nonresident decedent) other than the executor makes written application to the Secretary for determination of the amount of any estate tax for which the fiduciary may be personally liable, and for discharge from personal liability therefor, the Secretary upon the discharge of the executor from personal liability under subsection (a), or upon the expiration of 6 months after the making of such application by the fiduciary, if later, shall notify the fiduciary (1) of the amount of such tax for which it has been determined the fiduciary is liable, or (2) that it has been determined that the fiduciary is not liable for any such tax. Such application shall be accompanied by a copy of the instrument, if any, under which such fiduciary is acting, a description of the property held by the fiduciary, and such other information for purposes of carrying out the provisions of this section as the Secretary may require by regulations. On payment of the amount of such tax for which it has been determined the fiduciary is liable (other than any amount the time for payment of which has been extended under section 6161, 6163, or 6166), and on furnishing any bond which may be required for any amount for which the time for payment has been extended, or on receipt by him of notification of a determination that he is not liable for any such tax, the fiduciary shall be discharged from personal liability for any deficiency in such tax thereafter found to be due and shall be entitled to a receipt or writing evidencing such discharge.
+
+(c) Special lien under section 6324A For purposes of the second sentence of subsection (a) and the last sentence of subsection (b), an agreement which meets the requirements of section 6324A (relating to special lien for estate tax deferred under section 6166) shall be treated as the furnishing of bond with respect to the amount for which the time for payment has been extended under section 6166.
+
+(d) Good faith reliance on gift tax returns If the executor in good faith relies on gift tax returns furnished under section 6103(e)(3) for determining the decedent’s adjusted taxable gifts, the executor shall be discharged from personal liability with respect to any deficiency of the tax imposed by this chapter which is attributable to adjusted taxable gifts which—
+
+(1) are made more than 3 years before the date of the decedent’s death, and
+
+(2) are not shown on such returns.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 401; Pub. L. 91–614, title I, § 101(d)(1), (f), Dec. 31, 1970, 84 Stat. 1836, 1838; Pub. L. 94–455, title XIX, §§ 1902(a)(9), 1906(b)(13)(A), title XX, § 2004(d)(2), (f)(4), (6), Oct. 4, 1976, 90 Stat. 1805, 1834, 1870, 1872; Pub. L. 95–600, title VII, § 702(p)(1), Nov. 6, 1978, 92 Stat. 2937; Pub. L. 97–34, title IV, § 422(e)(1), (3), Aug. 13, 1981, 95 Stat. 316.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1981—Subsecs. (a) to (c). Pub. L. 97–34, § 422(e)(1), (3), struck out reference to section 6166A in subsecs. (a) and (b), and two such references in subsec. (c). 1978—Subsec. (d). Pub. L. 95–600 added subsec. (d). 1976—Subsec. (a). Pub. L. 94–455, §§ 1906(b)(13)(A), 2004(f)(6), substituted “6166 or 6166A” for “or 6166” after “6161, 6163” and struck out “or his delegate” in two places after “Secretary”. Subsec. (b). Pub. L. 94–455, §§ 1902(a)(9), 1906(b)(13)(A), 2004(f)(4), (6), substituted “6166 or 6166A” for “or 6166” after “6161, 6163”, “has been” for “has not been” after “payment of which”, and struck out “or his delegate” after “Secretary”. Subsec. (c). Pub. L. 94–455, § 2004(d)(2), added subsec. (c). 1970—Pub. L. 91–614, § 101(d)(1)(A), substituted “fiduciary” for “executor” in section catchline. Subsec. (a). Pub. L. 91–614, §§ 101(d)(1)(B), (C), (f), designated existing provisions as subsec. (a), inserted “General Rule—” immediately preceding first sentence and permitted a discharge of the executor even where an extension of time has been granted under sections 6161, 6163, or 6166 of this title, where a bond, if required, is provided to assure payment of taxes for which the extension was granted, and substituted “9 months” for “1 year” in two places. Subsec. (b). Pub. L. 91–614, § 101(d)(1)(D), added subsec. (b).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1981 AmendmentAmendment by Pub. L. 97–34 applicable to estates of decedents dying after Dec. 31, 1981, see section 422(f)(1) of Pub. L. 97–34, set out as a note under section 6166 of this title.
+
+Effective Date of 1978 AmendmentPub. L. 95–600, title VII, § 702(p)(2), Nov. 6, 1978, 92 Stat. 2937, provided that: “The amendment made by paragraph (1) [amending this section] shall apply with respect to the estates of decedents dying after December 31, 1976.”
+
+Effective Date of 1976 AmendmentAmendment by section 1902(a)(9) of Pub. L. 94–455 applicable in the case of estates of decedents dying after Dec. 31, 1970, see section 1902(c)(1) of Pub. L. 94–455, set out as a note under section 2012 of this title. Amendment by section 2004(d)(4) of Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2004(g) of Pub. L. 94–455, set out as a note under section 6166 of this title.
+
+Effective Date of 1970 AmendmentAmendment by section 101(d)(1) of Pub. L. 91–614 applicable with respect to decedents dying after Dec. 31, 1970, see section 101(j) of Pub. L. 91–614, set out as a note under section 2032 of this title. Pub. L. 91–614, title I, § 101(f), Dec. 31, 1970, 84 Stat. 1838, provided that the amendment made by that section is effective with respect to the estates of decedents dying after Dec. 31, 1973.

legal/us/code/title-26/chapter-11/section-2205.md

@@ -0,0 +1,35 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2205"
+description: "Reimbursement out of estate"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2205"
+citation: "26 U.S.C. § 2205"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2205"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "980cef5a649f04e2277063a3c80ef4f23580fe53e0e5079862f69cb4d58830c3"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "4704fb84650857e5a201c011a085a1a84533b00972b65001d2f98cbd8093a320"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2205 - Reimbursement out of estate
+
+## Text
+
+If the tax or any part thereof is paid by, or collected out of, that part of the estate passing to or in the possession of any person other than the executor in his capacity as such, such person shall be entitled to reimbursement out of any part of the estate still undistributed or by a just and equitable contribution by the persons whose interest in the estate of the decedent would have been reduced if the tax had been paid before the distribution of the estate or whose interest is subject to equal or prior liability for the payment of taxes, debts, or other charges against the estate, it being the purpose and intent of this chapter that so far as is practicable and unless otherwise directed by the will of the decedent the tax shall be paid out of the estate before its distribution.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 402.)

legal/us/code/title-26/chapter-11/section-2206.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2206"
+description: "Liability of life insurance beneficiaries"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2206"
+citation: "26 U.S.C. § 2206"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2206"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "49cfe40af0db790f47c4ff16e4cae098b4670a32521511fea72b52120e607d14"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "d3029eb5d0015a8f2d7c13c3d25290e69495e7d5b6606d9eebc843c926f6455e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2206 - Liability of life insurance beneficiaries
+
+## Text
+
+Unless the decedent directs otherwise in his will, if any part of the gross estate on which tax has been paid consists of proceeds of policies of insurance on the life of the decedent receivable by a beneficiary other than the executor, the executor shall be entitled to recover from such beneficiary such portion of the total tax paid as the proceeds of such policies bear to the taxable estate. If there is more than one such beneficiary, the executor shall be entitled to recover from such beneficiaries in the same ratio. In the case of such proceeds receivable by the surviving spouse of the decedent for which a deduction is allowed under section 2056 (relating to marital deduction), this section shall not apply to such proceeds except as to the amount thereof in excess of the aggregate amount of the marital deductions allowed under such section.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 402; Pub. L. 94–455, title XX, § 2001(c)(1)(H), Oct. 4, 1976, 90 Stat. 1852.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 substituted “the taxable estate” for “the sum of the taxable estate and the amount of the exemption allowed in computing the taxable estate, determined under section 2051” after “policies bear to”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.

legal/us/code/title-26/chapter-11/section-2207.md

@@ -0,0 +1,45 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2207"
+description: "Liability of recipient of property over which decedent had power of appointment"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2207"
+citation: "26 U.S.C. § 2207"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2207"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "16b926112210c710d18ff6dc042493feae2659687c4b4a32d44dabbf89d766fa"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "05215cf4853920d61885493ca7bf954556d8c9bafd36c1fa8153b0d54699ffba"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2207 - Liability of recipient of property over which decedent had power of appointment
+
+## Text
+
+Unless the decedent directs otherwise in his will, if any part of the gross estate on which the tax has been paid consists of the value of property included in the gross estate under section 2041, the executor shall be entitled to recover from the person receiving such property by reason of the exercise, nonexercise, or release of a power of appointment such portion of the total tax paid as the value of such property bears to the taxable estate. If there is more than one such person, the executor shall be entitled to recover from such persons in the same ratio. In the case of such property received by the surviving spouse of the decedent for which a deduction is allowed under section 2056 (relating to marital deduction), this section shall not apply to such property except as to the value thereof reduced by an amount equal to the excess of the aggregate amount of the marital deductions allowed under section 2056 over the amount of proceeds of insurance upon the life of the decedent receivable by the surviving spouse for which proceeds a marital deduction is allowed under such section.
+
+(Aug. 16, 1954, ch. 736, 68A Stat. 402; Pub. L. 94–455, title XX, § 2001(c)(1)(I), Oct. 4, 1976, 90 Stat. 1852.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1976—Pub. L. 94–455 substituted “the taxable estate” for “the sum of the taxable estate and the amount of the exemption allowed in computing the taxable estate, determined under section 2052, or section 2106(a), as the case may be” after “property bears to”.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1976 AmendmentAmendment by Pub. L. 94–455 applicable to estates of decedents dying after Dec. 31, 1976, see section 2001(d)(1) of Pub. L. 94–455, set out as a note under section 2001 of this title.

legal/us/code/title-26/chapter-11/section-2207a.md

@@ -0,0 +1,63 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2207A"
+description: "Right of recovery in the case of certain marital deduction property"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2207A"
+citation: "26 U.S.C. § 2207A"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2207A"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "b35e7366a2ca42e714ff7fbbc469dbc3e3452f24df4ebbb34d1f8b318fb886cf"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "d94f5e8c38fcb157150370d1088795c6dfe5b93df66affa75dda035181cc8f8c"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2207A - Right of recovery in the case of certain marital deduction property
+
+## Text
+
+(a) Recovery with respect to estate tax (1) In general If any part of the gross estate consists of property the value of which is includible in the gross estate by reason of section 2044 (relating to certain property for which marital deduction was previously allowed), the decedent’s estate shall be entitled to recover from the person receiving the property the amount by which—
+
+(A) the total tax under this chapter which has been paid, exceeds
+
+(B) the total tax under this chapter which would have been payable if the value of such property had not been included in the gross estate.
+
+(2) Decedent may otherwise direct Paragraph (1) shall not apply with respect to any property to the extent that the decedent in his will (or a revocable trust) specifically indicates an intent to waive any right of recovery under this subchapter with respect to such property.
+
+(b) Recovery with respect to gift tax If for any calendar year tax is paid under chapter 12 with respect to any person by reason of property treated as transferred by such person under section 2519, such person shall be entitled to recover from the person receiving the property the amount by which—
+
+(1) the total tax for such year under chapter 12, exceeds
+
+(2) the total tax which would have been payable under such chapter for such year if the value of such property had not been taken into account for purposes of chapter 12.
+
+(c) More than one recipient of property For purposes of this section, if there is more than one person receiving the property, the right of recovery shall be against each such person.
+
+(d) Taxes and interest In the case of penalties and interest attributable to additional taxes described in subsections (a) and (b), rules similar to subsections (a), (b), and (c) shall apply.
+
+(Added Pub. L. 97–34, title IV, § 403(d)(4)(A), Aug. 13, 1981, 95 Stat. 304; amended Pub. L. 105–34, title XIII, § 1302(a), Aug. 5, 1997, 111 Stat. 1039.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1997—Subsec. (a)(2). Pub. L. 105–34 amended heading and text of par. (2) generally. Prior to amendment, text read as follows: “Paragraph (1) shall not apply if the decedent otherwise directs by will.”
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1997 AmendmentPub. L. 105–34, title XIII, § 1302(c), Aug. 5, 1997, 111 Stat. 1039, provided that: “The amendments made by this section [amending this section and section 2207B of this title] shall apply with respect to the estates of decedents dying after the date of the enactment of this Act [Aug. 5, 1997].”
+
+Effective DateSection applicable to estates of decedents dying after Dec. 31, 1981, see section 403(e) of Pub. L. 97–34, set out as an Effective Date of 1981 Amendment note under section 2056 of this title.

legal/us/code/title-26/chapter-11/section-2207b.md

@@ -0,0 +1,61 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2207B"
+description: "Right of recovery where decedent retained interest"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2207B"
+citation: "26 U.S.C. § 2207B"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2207B"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "35fcf54f4c5f638c9cccc2b45b60b8218a323e975e3517aea6e324c980ba09e8"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "b10eb5f7ea8660d4e716772c652763fee0b3e868d10965150d689d57f7d54764"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2207B - Right of recovery where decedent retained interest
+
+## Text
+
+(a) Estate tax (1) In general If any part of the gross estate on which tax has been paid consists of the value of property included in the gross estate by reason of section 2036 (relating to transfers with retained life estate), the decedent’s estate shall be entitled to recover from the person receiving the property the amount which bears the same ratio to the total tax under this chapter which has been paid as—
+
+(A) the value of such property, bears to
+
+(B) the taxable estate.
+
+(2) Decedent may otherwise direct Paragraph (1) shall not apply with respect to any property to the extent that the decedent in his will (or a revocable trust) specifically indicates an intent to waive any right of recovery under this subchapter with respect to such property.
+
+(b) More than one recipient For purposes of this section, if there is more than 1 person receiving the property, the right of recovery shall be against each such person.
+
+(c) Penalties and interest In the case of penalties and interest attributable to the additional taxes described in subsection (a), rules similar to the rules of subsections (a) and (b) shall apply.
+
+(d) No right of recovery against charitable remainder trusts No person shall be entitled to recover any amount by reason of this section from a trust to which section 664 applies (determined without regard to this section).
+
+(Added Pub. L. 100–647, title III, § 3031(f)(1), Nov. 10, 1988, 102 Stat. 3637; amended Pub. L. 101–508, title XI, § 11601(b)(1), Nov. 5, 1990, 104 Stat. 1388–490; Pub. L. 105–34, title XIII, § 1302(b), Aug. 5, 1997, 111 Stat. 1039.)
+
+## Notes
+
+Editorial Notes
+
+Amendments1997—Subsec. (a)(2). Pub. L. 105–34 amended heading and text of par. (2) generally. Prior to amendment, text read as follows: “Paragraph (1) shall not apply if the decedent otherwise directs in a provision of his will (or a revocable trust) specifically referring to this section.” 1990—Subsec. (b). Pub. L. 101–508, § 11601(b)(1)(A), redesignated former subsec. (c) as (b) and struck out former subsec. (b) which read as follows: “If for any calendar year tax is paid under chapter 12 with respect to any person by reason of property treated as transferred by such person under section 2036(c)(4), such person shall be entitled to recover from the original transferee (as defined in section 2036(c)(4)(C)(ii)) the amount which bears the same ratio to the total tax for such year under chapter 12 as— “(1) the value of such property for purposes of chapter 12, bears to “(2) the total amount of the taxable gifts for such year.” Subsec. (c). Pub. L. 101–508, § 11601(b)(1), redesignated subsec. (d) as (c) and substituted “subsection (a)” for “subsections (a) and (b)” and “subsections (a) and (b)” for “subsections (a), (b), and (c)”. Former subsec. (c) redesignated (b). Subsecs. (d), (e). Pub. L. 101–508, § 11601(b)(1)(A), redesignated subsecs. (d) and (e) as (c) and (d), respectively. Former subsec. (d) redesignated (c).
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of 1997 AmendmentAmendment by Pub. L. 105–34 applicable with respect to estates of decedents dying after Aug. 5, 1997, see section 1302(c) of Pub. L. 105–34, set out as a note under section 2207A of this title.
+
+Effective Date of 1990 AmendmentAmendment by Pub. L. 101–508 applicable in the case of property transferred after Dec. 17, 1987, see section 11601(c) of Pub. L. 101–508, set out as a note under section 2036 of this title.
+
+Effective DateSection effective as if included in provisions of Revenue Act of 1987, Pub. L. 100–203, title X, except that if an amount is included in the gross estate of a decedent under section 2036 of this title other than solely by reason of section 2036(c) of this title, section applicable to such amount only with respect to property transferred after Nov. 10, 1988, see section 3031(h)(1), (3) of Pub. L. 100–647, set out as an Effective Date of 1988 Amendment note under section 2036 of this title.

legal/us/code/title-26/chapter-11/section-2208.md

@@ -0,0 +1,41 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2208"
+description: "Certain residents of possessions considered citizens of the United States"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2208"
+citation: "26 U.S.C. § 2208"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2208"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "142f43a3a50f1dace9704ee2f0bf8283bc1d571bcd545ed9871ab23c72e27ef7"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "730642f9d1b5636c9b792930e57fa78c08d968096818ec86bfef7030dd68c016"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2208 - Certain residents of possessions considered citizens of the United States
+
+## Text
+
+A decedent who was a citizen of the United States and a resident of a possession thereof at the time of his death shall, for purposes of the tax imposed by this chapter, be considered a “citizen” of the United States within the meaning of that term wherever used in this title unless he acquired his United States citizenship solely by reason of (1) his being a citizen of such possession of the United States, or (2) his birth or residence within such possession of the United States.
+
+(Added Pub. L. 85–866, title I, § 102(a), Sept. 2, 1958, 72 Stat. 1674.)
+
+## Notes
+
+Statutory Notes and Related Subsidiaries
+
+Effective DateSection applicable to estates of decedents dying after Sept. 2, 1958, see section 102(d) of Pub. L. 85–866, set out as an Effective Date of 1958 Amendment note under section 2014 of this title.

legal/us/code/title-26/chapter-11/section-2209.md

@@ -0,0 +1,41 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2209"
+description: "Certain residents of possessions considered nonresidents not citizens of the United States"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2209"
+citation: "26 U.S.C. § 2209"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2209"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "dfe76625b29bd03a52a535e5449239cac17489d5a10dc776b68d9ecee03c73d3"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "155765a725066b2aa2d284ac2f1e88aaecad911d6a06f010fb7bc27319c2d88d"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2209 - Certain residents of possessions considered nonresidents not citizens of the United States
+
+## Text
+
+A decedent who was a citizen of the United States and a resident of a possession thereof at the time of his death shall, for purposes of the tax imposed by this chapter, be considered a “nonresident not a citizen of the United States” within the meaning of that term wherever used in this title, but only if such person acquired his United States citizenship solely by reason of (1) his being a citizen of such possession of the United States, or (2) his birth or residence within such possession of the United States.
+
+(Added Pub. L. 86–779, § 4(b)(1), Sept. 14, 1960, 74 Stat. 999.)
+
+## Notes
+
+Statutory Notes and Related Subsidiaries
+
+Effective DateSection applicable with respect to estates of decedents dying after Sept. 14, 1960, see section 4(e)(2) of Pub. L. 86–779, set out as an Effective Date of 1960 Amendment note under section 2106 of this title.

legal/us/code/title-26/chapter-11/section-2210.md

@@ -0,0 +1,39 @@
+---
+type: "LegalText"
+title: "26 U.S.C. § 2210"
+description: "Repealed. Pub. L. 111–312, title III, § 301(a), Dec. 17, 2010, 124 Stat. 3300]"
+jurisdiction: "us"
+corpus: "united_states_code"
+kind: "code_section"
+title_number: 26
+title_name: "INTERNAL REVENUE CODE"
+chapter_number: "11"
+chapter_name: "ESTATE TAX"
+section: "2210"
+citation: "26 U.S.C. § 2210"
+status: "current"
+release_point: "119-100"
+release_date: "2026-06-26"
+source: "official"
+source_url: "https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip"
+source_identifier: "/us/usc/t26/s2210"
+source_file: "data/legal/raw/us/code/title-26/usc26.xml"
+source_hash: "ddabe7f19a212eb498c17f5c61e40cf4b53c6f576a761b3a63adbd8ef9abff3e"
+raw_snapshot_hash: "a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4"
+text_hash: "4b7b7bca0cd1b0ab8c464e959051523a83e0f39c3f6b6cf5059e9c6a9ebad64e"
+retrieved_at: "2026-07-04"
+confidence: "official"
+tags: ["legal", "us-code"]
+---
+
+# 26 U.S.C. § 2210 - Repealed. Pub. L. 111–312, title III, § 301(a), Dec. 17, 2010, 124 Stat. 3300]
+
+## Notes
+
+Section, added Pub. L. 107–16, title V, § 501(a), June 7, 2001, 115 Stat. 69, related to termination of applicability of chapter to estates of decedents dying after Dec. 31, 2009.
+
+A prior section 2210, added Pub. L. 98–369, div. A, title V, § 544(a), July 18, 1984, 98 Stat. 892; amended Pub. L. 99–514, title XVIII, §§ 1854(d)(1)(A), (2)–(6), 1899A(37), Oct. 22, 1986, 100 Stat. 2879, 2880, 2960, related to liability for payment in case of transfer of employer securities to an employee stock ownership plan or a worker-owned cooperative, prior to repeal by Pub. L. 101–239, title VII, § 7304(b)(1), (3), Dec. 19, 1989, 103 Stat. 2353, applicable to estates of decedents dying after July 12, 1989.
+
+Statutory Notes and Related Subsidiaries
+
+Effective Date of RepealRepeal of section applicable to estates of decedents dying, and transfers made after Dec. 31, 2009, except as otherwise provided, see section 301(e) of Pub. L. 111–312, set out as an Effective and Termination Dates of 2010 Amendment note under section 121 of this title.