Internal Revenue Code Sections 877A and 2801 were created by the HEART Act to impose a mark-to-market exit tax on citizens wishing to expatriate, and to impose a wealth transfer tax upon U.S. gift recipients of an expatriate's wealth. The idea is for expatriating citizens to pay their taxes,...

Overview of the estate and gift taxes -- The gift tax -- The gross estate : property owned at death -- The gross estate : transfers during life -- Deductions and credits -- The generation-skipping transfer tax -- Valuation of property -- Payment, collection, and apportionment.

The objective of this paper is two-fold. First, we describe and compare the gift and bequest (estate) tax systems in the United States and Japan. Second, we use tax data to estimate the magnitude of intergenerational transfers. The magnitude of intergenerational transfers provides aid in...

This paper describes the current estate and gift tax rules that apply to intergenerational transfers in the United States. It summarizes the incentives for inter vivos giving as a strategy for reducing estate tax liability. It shows that the current level of intergenerational transfers is much...