This work is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, Chapter 33 (Matthew Bender & Co., Inc.), the publication of which derivative work is permitted by Matthew Bender & Co., Inc.
This article is Part II of a three-part review of the tax consequences of gifts made by nonresident aliens. Part I examined how gifts of U.S. real estate and tangible property by nonresident aliens (NRAs) could be subject to U.S. gift tax. Part II explores the gift tax implications of intangible property. Part III will review deductions and exclusions, as well as the applicable tax rates.