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10 January 2025

Final regulations issued on the taxation of certain gifts and bequests from covered expats

The IRS and Treasury Department on January 10, 2025, issued final regulations (TD 10027) under IRC Section 2801 with guidance on the application, reporting and payment of tax on gifts or bequests directly or indirectly received by US citizens, residents and certain trusts from covered individuals who have relinquished their US citizenship or are no longer lawful residents. The final regulations adopt the September 2015 proposed regulations (see Tax Alert 2015-1765) with some modification. A Tax Alert is forthcoming.

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Published by NTD’s Tax Technical Knowledge Services group; Chris DeZinno, legal editor

Document ID: 2025-0198

 

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