Tax Facts

841 / What additional amounts may be includable in a decedent’s gross estate?

IRC Section 2701 Recapture of Qualified Payments


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.

2.    IRC § 2704.


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