Dina Kapur Sanna wrote about recently issued proposed
regulations for the Trust & Estates Magazine,
e-newsletter: "IRS Issues Proposed Regs Taxing Gifts and Bequests
From Covered Expatriates." The article discussed recent
guidance that has been issued to implement Internal Revenue Code
Section 2801, enacted more than eight years ago, which imposes a
succession tax on U.S. citizens and residents who receive gifts or
bequests from individuals who relinquished U.S. citizenship or
ceased to be lawful permanent residents of the United States on or
after June 17, 2008 and met the tests to be so-called "covered
expatriates."
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