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Title 26 — Internal Revenue CodeRelease 119-73not60

§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

Last updated Apr 5, 2026|Official source

Summary

If payment of the tax is postponed under section 6163(a), the part of estate, inheritance, legacy, or succession taxes that qualifies for a credit under section 2014 and that comes from a reversionary or remainder interest can be used to reduce the tax on that interest. This is allowed only up to the limits in those sections and only if that tax is paid and the credit claimed before the extended payment deadline under section 6163.

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 5, 2026

Release point: 119-73not60