Title 26 — Internal Revenue CodeRelease 119-73
§2015 Credit for Death Taxes on Remainders
Title 26 › Subtitle Subtitle B— Estate and Gift Taxes › Chapter 11— ESTATE TAX › Subchapter A— Estates of Citizens or Residents › Part II— CREDITS AGAINST TAX › § 2015
Summary
When an estate elects to postpone paying estate tax on a reversionary or remainder interest, the credit for foreign death taxes tied to that interest can still be claimed. The foreign taxes must be paid, and the credit claimed, before the postponed and extended payment deadline runs out, and the usual limits on the credit amount still apply.
Full Legal Text
Title 26, §2015
Internal Revenue Code — Source: USLM XML via OLRC
Where an election is made under section 6163(a) to postpone payment of the tax imposed by section 2001, or 2101, such part of any estate, inheritance, legacy, or succession taxes allowable as a credit under section 2014, as is attributable to a reversionary or remainder interest may be allowed as a credit against the tax attributable to such interest, subject to the limitations on the amount of the credit contained in such sections, if such part is paid, and credit therefor claimed, at any time before the expiration of the time for payment of the tax imposed by section 2001 or 2101 as postponed and extended under section 6163.
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Amendments
2001—Pub. L. 107–16 struck out “2011 or” before “2014”. 1958—Pub. L. 85–866 substituted “the time for payment of the tax imposed by section 2001 or 2101 as postponed and extended under section 6163” for “60 days after the termination of the precedent interest or interests in the property”.
Statutory Notes and Related Subsidiaries
Effective Date
of 2001 AmendmentAmendment by Pub. L. 107–16 applicable to estates of decedents dying, and generation-skipping transfers, after Dec. 31, 2004, see section 532(d) of Pub. L. 107–16, set out as a note under section 2012 of this title.
Effective Date
of 1958 Amendment Pub. L. 85–866, title I, § 66(a)(3), Sept. 2, 1958, 72 Stat. 1658, provided that: “The
Amendments
made by paragraphs (1) and (2) [amending this section and section 927 of I.R.C. 1939] shall apply in the case of any reversionary or remainder interest in property only if the precedent interest or interests in the property did not terminate before the beginning of the 60-day period which ends on the date of the enactment of this Act [Sept. 2, 1958].”
Reference
Citations & Metadata
Citation
26 U.S.C. § 2015
Title 26 — Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73