The inheritance tax section of Internal Revenue Code Section 2801 will soon become effective, bringing with it unique and difficult challenges for advisors and taxpayers. While the U.S. estate and gift tax systems impose obligations on the donor, the IRC Section 2801 inheritance tax requires the donee to prove a negative or pay a 40 percent inheritance tax. Specifically, whenever a U.S. domiciliary receives a gift, bequest or distribution from a foreign trust, the proposed regulations require
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