Final regulations under Section 2801, Regarding the Imposition of Tax on Certain Gifts and Bequests from Covered Expatriates published
Section 301 of the Heroes Earning Assistance and Relief Tax Act of 2008, Pub. L. 110-245 (122 Stat. 1624) (the HEART Act) added Chapter 15 (Gifts and Bequests from Expatriates) to subtitle B, effective June 17, 2008. Chapter 15 consists solely of section 2801 and imposes a tax (the section 2801 tax) on certain transfers of property by gift or bequest (covered gifts and covered bequests) from certain individuals who expatriate on or after June 17, 2008 (covered expatriates). The final regulations, Guidance under Section 2801 Regarding the Imposition of Tax on Certain Gifts and Bequests from Covered Expatriates , apply to covered gifts and covered bequests received on or after January 1, 2025. Form 708, United States Return of Tax for Gifts and Bequests Received from Covered Expatriates PDF and the Instructions to the Form 708 United States Return of Tax for Gifts and Bequests Received from Covered Expatriates PDF are now available.