Reg. § 28.2801-1 Tax on certain gifts and bequests from covered expatriates.
(a) In general Section of the Internal Revenue Code (Code) imposes a tax (section tax) on covered gifts and covered bequests, including distributions attributable to covered gifts and covered bequests from non-electing foreign trusts, received by a U.S. citizen or resident from a covered expatriate during a calendar year. Domestic trusts, as well as electing foreign trusts, are subject to tax under section in the same manner as if the trusts were U.S. citizens. See section and (B)(iii). Accordingly, the section tax is paid by the U.S. citizen or resident, domestic trust, or electing foreign trust that receives the covered gift or covered bequest, including distributions attributable to covered gifts and covered bequests from non-electing foreign trusts. For purposes of the regulations in this part 28 (26 CFR part 28), references to U.S. citizens are considered to include domestic trusts and electing foreign trusts.
(b) Applicability date This section applies to covered gifts or covered bequests received on or after January 1, 2025.