Title 26, Internal Revenue CodeRelease 119-110
§2519 Dispositions of Certain Life Estates
Title 26 › Subtitle B — Estate and Gift Taxes › CHAPTER 12 — GIFT TAX › Subchapter B — Transfers › § 2519
Summary
Treats any transfer of all or part of a qualifying life-income interest in property as if the donor had transferred all the other interests in that property for the tax rules in this chapter and chapter 11. It only applies to property that gave the donor a deduction under section 2056(b)(7) or section 2523(f). For recovery of gift tax, see section 2207A(b).
Full Legal Text
Title 26, §2519
Internal Revenue Code, Source: USLM XML via OLRC
(a)General rule
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)Property to which this subsection applies
This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor— (1)
(2)under section 2523 by reason of subsection (f) thereof.
(c)Cross reference
For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).
Legislative History
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.
Reference
Citations & Metadata
Citation
26 U.S.C. § 2519
Title 26, Internal Revenue Code
Last Updated
Sep 22, 2026
Release point: 119-110