§2519 — Title 26 Internal Revenue Code | U.S. Code

Summary

Treat any transfer where a person gives all or part of a qualifying life-income interest in property as if that person had transferred every other interest in that property for the tax rules in this chapter and in chapter 11. That rule only applies if a deduction was allowed when the property was transferred to the person who gave it under section 2056(b)(7) or section 2523(f); for rules about recovering gift tax in these cases, see section 2207A(b).

Title 26, §2519

Internal Revenue Code — Source: USLM XML via OLRC

(a)For purposes of this chapter and chapter 11, any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of all interests in such property other than the qualifying income interest.

(b)This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor—

(1)under section 2056 by reason of subsection (b)(7) thereof, or

(2)under section 2523 by reason of subsection (f) thereof.

(c)For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).

Notes & Related Subsidiaries

Editorial Notes

Amendments

1983—Pub. L. 97–448, § 104(a)(3)(B), amended directory language of Pub. L. 97–34, § 403(d)(3)(B)(i), to clarify that this section be inserted at end of subchapter B of chapter 12, rather than at end of subchapter B of chapter 11, and did not involve any change in text. Subsec. (a). Pub. L. 97–448, § 104(a)(3)(A), substituted “For purposes of this chapter and chapter 11, any disposition” for “Any disposition” and “treated as a transfer of all interests in such property other than the qualifying income interest” for “treated as a transfer of such property”. Subsec. (c). Pub. L. 97–448, § 104(a)(7), added subsec. (c).

Statutory Notes and Related Subsidiaries

Effective Date

of 1983 AmendmentAmendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

Effective Date

Section applicable to gifts made after Dec. 31, 1981, see section 403(e)(2) of Pub. L. 97–34, set out as an

Effective Date

of 1981 Amendment note under section 2056 of this title.

§2519 Dispositions of certain life estates

Summary

Title 26, §2519

Notes & Related Subsidiaries

Editorial Notes

Amendments

Statutory Notes and Related Subsidiaries

Effective Date

Effective Date

Effective Date

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