26 USC 2511 – Transfers in general
(a) Scope
Subject to the limitations contained in this chapter, the tax imposed by section 2501 shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; but in the case of a nonresident not a citizen of the United States, shall apply to a transfer only if the property is situated within the United States.
(b) Intangible property
Terms Used In 26 USC 2511
- domestic: when applied to a corporation or partnership means created or organized in the United States or under the law of the United States or of any State unless, in the case of a partnership, the Secretary provides otherwise by regulations. See 26 USC 7701
- Gift: A voluntary transfer or conveyance of property without consideration, or for less than full and adequate consideration based on fair market value.
- State: shall be construed to include the District of Columbia, where such construction is necessary to carry out provisions of this title. See 26 USC 7701
- stock: includes shares in an association, joint-stock company, or insurance company. See 26 USC 7701
- United States: when used in a geographical sense includes only the States and the District of Columbia. See 26 USC 7701
- United States person: means &mdash. See 26 USC 7701
For purposes of this chapter, in the case of a nonresident not a citizen of the United States who is excepted from the application of section 2501(a)(2)—
(1) shares of stock issued by a domestic corporation, and
(2) debt obligations of—
(A) a United States person, or
(B) the United States, a State or any political subdivision thereof, or the District of Columbia,
which are owned and held by such nonresident shall be deemed to be property situated within the United States.