Treasury Regulations · 26 CFR
§ 20.2208-1. Certain residents of possessions considered citizens of the United States.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 2208
Cite as 26 CFR § 20.2208-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- January 19, 1961 by T.D. 6526
- Issued under
- 26 U.S.C. § 2208
- Length
- 255 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 2 regulations; cited by 2
As used in this part, the term “citizen of the United States” is considered to include a decedent dying after September 2, 1958, who, at the time of his death, was domiciled in a possession of the United States and was a United States citizen, and who did not acquire his United States citizenship solely by reason of his being a citizen of such possession or by reason of his birth or residence within such possession. The estate of such a decedent is, therefore, subject to the tax imposed by section 2001. See paragraph (a)(2) of § 20.0-1 and § 20.2209-1 for further information relating to the application of the Federal estate tax to the estates of decedents who were residents of possessions of the United States. The application of this section may be illustrated by the following example and the examples set forth in § 20.2209-1:
A, a citizen of the United States by reason of his birth in the United States at San Francisco, established residence in Puerto Rico and acquired a Puerto Rican citizenship. A died on September 4, 1958, while a citizen and domiciliary of Puerto Rico. A's estate is, by reason of the provisions of section 2208, subject to the tax imposed by section 2001 inasmuch as his United States citizenship is based on birth in the United States and is not based solely on being a citizen of a possession or solely on birth or residence in a possession.
[T.D. 6526, 26 FR 417, Jan. 19, 1961]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 2208 Certain residents of possessions considered citizens of the United States
- § 2001 Imposition and rate of tax
Regulations it cites
- § 20.0-1 Introduction.
- § 20.2209-1 Certain residents of possessions considered nonresidents not citizens of the United States.
Cited by 2 other regulations
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 6526 (26 FR 417)
Where it sits in 26 CFR
- Subchapter B Estate and gift taxes
- Part 20 Estate tax; estates of decedents dying after august 16, 1954
- Miscellaneous
Nearby sections
- § 20.2206-1 Liability of life insurance beneficiaries.
- § 20.2207-1 Liability of recipient of property over which decedent had power of appointment.
- § 20.2207A-1 Right of recovery of estate taxes in the case of certain marital deduction property.
- § 20.2207A-2 Effective date.
- § 20.2208-1 Certain residents of possessions considered citizens of the United States.
- § 20.2209-1 Certain residents of possessions considered nonresidents not citizens of the United States.