Title 26 — Internal Revenue CodeRelease 119-73
§2208 Certain Residents of Possessions Considered Citizens of the United States
Title 26 › Subtitle Subtitle B— Estate and Gift Taxes › Chapter 11— ESTATE TAX › Subchapter C— Miscellaneous › § 2208
Summary
Someone who dies as a U.S. citizen living in a U.S. possession is treated as a U.S. citizen for estate tax purposes. The exception is a person whose citizenship came only from being a citizen of that possession or from being born or living there.
Full Legal Text
Title 26, §2208
Internal Revenue Code — Source: USLM XML via OLRC
A decedent who was a citizen of the United States and a resident of a possession thereof at the time of his death shall, for purposes of the tax imposed by this chapter, be considered a “citizen” of the United States within the meaning of that term wherever used in this title unless he acquired his United States citizenship solely by reason of (1) his being a citizen of such possession of the United States, or (2) his birth or residence within such possession of the United States.
Legislative History
Notes & Related Subsidiaries
Statutory Notes and Related Subsidiaries
Effective Date
Section applicable to estates of decedents dying after Sept. 2, 1958, see section 102(d) of Pub. L. 85–866, set out as an
Effective Date
of 1958 Amendment note under section 2014 of this title.
Reference
Citations & Metadata
Citation
26 U.S.C. § 2208
Title 26 — Internal Revenue Code
Last Updated
Apr 6, 2026
Release point: 119-73