Additional estate tax may be due with respect to certain transfers of interests in corporations or partnerships to reflect cumulative but unpaid distributions on retained interests (see Q 934).1
IRC Section 2704 Deemed Transfer of Lapsing Right
There may be a deemed transfer at death upon the lapse of certain voting or liquidation rights in a corporation or partnership (see Q 943).2
IRC Section 2801 Property Received from Expatriate
A United States citizen or resident who receives a covered bequest from certain expatriates may owe estate tax on the transfer.
1. IRC § 2701.