Treasury Finalizes Regulations Taxing Gifts and Bequests from Covered Expatriates
By Ian Weinstock and Heather Fincher After 15 years of waiting, we now have final regulations providing guidance on the tax imposed by Internal Revenue Code Section 2801 (the “Section 2801 tax”) for U.S. citizens and residents who receive gifts or bequests from certain individuals who have expatriated from the