ESTATE TAX, GIFT TAX

T.D. 10027, page 897. The final Treasury Decision provides guidance for section 2801, which was added to the Internal Revenue Code by section 301 of the Heroes Earnings Assistance and Relief Tax Act of 2008, Public Law 110–245 (122 Stat. 1624), effective June 17, 2008. Section 2801, which is the sole section of new Chapter 15 of subtitle B (relating to taxes on transfers of property), imposes a transfer tax on U.S. citizens and residents, including trusts, who receive, directly or indirectly, covered gifts and covered bequests from covered expatriates.