§ 2501. Imposition of tax
(a)
Taxable transfers
(1)
General rule
A tax, computed as provided in section
2502, is hereby imposed for each calendar year on the transfer of property by gift during such calendar year by any individual resident or nonresident.
(2)
Transfers of intangible property
Except as provided in paragraph (3), paragraph (1) shall not apply to the transfer of intangible property by a nonresident not a citizen of the United States.
(5)
Transfers of certain stock
(A)
In general
In the case of a transfer of stock in a foreign corporation described in subparagraph (B) by a donor to whom section
877
(b) applies for the taxable year which includes the date of the transfer—
(B)
Foreign corporation described
A foreign corporation is described in this subparagraph with respect to a donor if—
(i)
the donor owned (within the meaning of section
958
(a)) at the time of such transfer 10 percent or more of the total combined voting power of all classes of stock entitled to vote of the foreign corporation, and
(ii)
such donor owned (within the meaning of section
958
(a)), or is considered to have owned (by applying the ownership rules of section
958
(b)), at the time of such transfer, more than 50 percent of—
(C)
U.S.-asset value
For purposes of subparagraph (A), the U.S.-asset value of stock shall be the amount which bears the same ratio to the fair market value of such stock at the time of transfer as—
(b)
Certain residents of possessions considered citizens of the United States
A donor who is a citizen of the United States and a resident of a possession thereof shall, for purposes of the tax imposed by this chapter, be considered a “citizen” of the United States within the meaning of that term wherever used in this title unless he acquired his United States citizenship solely by reason of
(c)
Certain residents of possessions considered nonresidents not citizens of the United States
A donor who is a citizen of the United States and a resident of a possession thereof shall, for purposes of the tax imposed by this chapter, be considered a “nonresident not a citizen of the United States” within the meaning of that term wherever used in this title, but only if such donor acquired his United States citizenship solely by reason of