26 U.S.C. § 2511
Section 2511 · Transfers in general
Current version, with additions and removals from the March 9, 2002 version.
Subject to the limitations contained in this chapter, the tax imposed by section 2501 shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; but in the case of a nonresident not a citizen of the United States, shall apply to a transfer only if the property is situated within the United States.
Subject to the limitations contained in this chapter, the tax imposed by section 2501 shall apply whether the transfer is in trust or otherwise, whether the gift is direct or indirect, and whether the property is real or personal, tangible or intangible; but in the case of a nonresident not a citizen of the United States, shall apply to a transfer only if the property is situated within the United States.
For purposes of this chapter, in the case of a nonresident not a citizen of the United States who is excepted from the application of section 2501(a)(2)—
For purposes of this chapter, in the case of a nonresident not a citizen of the United States who is excepted from the application of section 2501(a)(2)—
(1) shares of stock issued by a domestic corporation, and
(1) shares of stock issued by a domestic corporation, and
(2) debt obligations of—
(2) debt obligations of—
(A) a United States person, or
(A) a United States person, or
(B) the United States, a State or any political subdivision thereof, or the District of Columbia,
(B) the United States, a State or any political subdivision thereof, or the District of Columbia,
which are owned and held by such nonresident shall be deemed to be property situated within the United States.
which are owned and held by such nonresident shall be deemed to be property situated within the United States.
Notwithstanding any other provision of this section and except as provided in regulations, a transfer in trust shall be treated as a transfer of property by gift, unless the trust is treated as wholly owned by the donor or the donor's spouse under subpart E of part I of subchapter J of chapter 1.