- 5 - deduction is limited to “transfers to corporations and associations created or organized in the United States, and to trustees for use within the United States”. Sec. 20.2106- 1(a)(2)(i), Estate Tax Regs.; see sec. 2106(a)(2)(A)(ii). This deduction may not exceed the value of the transferred property required to be included in the gross estate. Sec. 2106(a)(2)(D). Decedent did not make a bequest to a corporation or association created or organized in the United States; decedent made all relevant bequests to Canadian-registered organizations described in paragraph 1 of article XXI of the convention.4 We conclude 3(...continued) citizen of the United States shall be determined by deducting from the value of that part of his gross estate which at the time of his death is situated in the United States-- * * * * * * * (2) Transfers for public, charitable, and religious uses.-- (A) In general.- The amount of all bequests, legacies, devises, or transfers * * * * * * * * * * (ii) to or for the use of any domestic corporation organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes, * * *. 4 We note that the estate did not argue that the bequests, although made to Canadian-registered organizations, were ultimately used in the United States. Cf. Estate of McAllister (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011