§ 2101 Tax imposed
(a) Imposition
Except as provided in section , a tax is hereby imposed on the transfer of the taxable estate (determined as provided in section ) 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 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 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 as modified by section ) 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 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.)
Operative text only. Editorial notes, amendment history, and effective dates: official OLRC text of § 2101