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26 U.S.C. § 2105

Property without the United States

United States · Title 26 — INTERNAL REVENUE CODE · Status: effective

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26 U.S.C. § 2105, Property without the United States, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/463194
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For purposes of this subchapter, the amount receivable as insurance on the life of a nonresident not a citizen of the United States shall not be deemed property within the United States. For purposes of this subchapter, the following shall not be deemed property within the United States— For purposes of this subchapter, works of art owned by a nonresident not a citizen of the United States shall not be deemed property within the United States if such works of art are— For purposes of this subchapter, stock in a regulated investment company (as defined in section 851) owned by a nonresident not a citizen of the United States shall not be deemed property within the United States in the proportion that, at the end of the quarter of such investment company’s taxable year immediately preceding a decedent’s date of death (or at such other time as the Secretary may designate in regulations), the assets of the investment company that were qualifying assets with respect to the decedent bore to the total assets of the investment company. For purposes of this subsection, qualifying assets with respect to a decedent are assets that, if owned directly by the decedent, would have been— This subsection shall not apply to estates of decedents dying after December 31, 2011.

Legislative history

The public laws that enacted or amended this section. Tallies are for the whole bill as it passed each chamber — often an omnibus covering far more than this provision — not a vote on this section alone. The law that originally enacted this section predates the public laws loaded here, so only later amendments are listed.

  • Amended byPub. L. 98-369(H.R. 4170)1984-07-18
    Deficit Reduction Act of 1984
    House: no recorded tallySenate: no recorded tally
  • Amended byPub. L. 100-647(H.R. 4333)1988-11-10
    Technical and Miscellaneous Revenue Act of 1988
    House: no recorded tallySenate: no recorded tally
  • Amended byPub. L. 103-66(H.R. 2264)1993-08-10
    Omnibus Budget Reconciliation Act of 1993
  • Amended byPub. L. 105-34(H.R. 2014)1997-08-05
    Taxpayer Relief Act of 1997
  • Amended byPub. L. 108-357(H.R. 4520)2004-10-22
    American Jobs Creation Act of 2004
  • Amended byPub. L. 110-343(H.R. 1424)2008-10-03
    A bill to provide authority for the Federal Government to purchase and insure certain types of troubled assets for the purposes of providing stability to and preventing disruption in the economy and financial system and protecting taxpayers, to amend the Internal Revenue Code of 1986 to provide incentives for energy production and conservation, to extend certain expiring provisions, to provide individual income tax relief, and for other purposes.
  • Amended byPub. L. 111-312(H.R. 4853)2010-12-17
    Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010
    House: 277–148Senate: no recorded tally