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Treasury Regulations · 26 CFR Part 28

Part 28. Imposition of tax on gifts and bequests from covered expatriates

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 Title 26 on ecfr.gov (external site) or the official annual CFR on govinfo (external site).

  1. § 28.2801-0 Table of contents.
  2. § 28.2801-1 Tax on certain gifts and bequests from covered expatriates.
  3. § 28.2801-2 Definitions.
  4. § 28.2801-3 Rules and exceptions applicable to covered gifts and covered bequests.
  5. § 28.2801-4 Liability for and payment of tax on covered gifts and covered bequests; computation of tax.
  6. § 28.2801-5 Foreign trusts.
  7. § 28.2801-6 Special rules and cross-references.
  8. § 28.2801-7 Determining responsibility under section 2801.
  9. § 28.6001-1 Records required to be kept.
  10. § 28.6011-1 Returns.
  11. § 28.6060-1 Reporting requirements for tax return preparers.
  12. § 28.6071-1 Time for filing returns.
  13. § 28.6081-1 Extension of time for filing returns reporting gifts and bequests from covered expatriates.
  14. § 28.6091-1 Place for filing returns.
  15. § 28.6101-1 Period covered by returns.
  16. § 28.6107-1 Tax return preparer must furnish copy of return or claim for refund to taxpayer and must retain a copy or record.
  17. § 28.6109-1 Tax return preparers furnishing identifying numbers for returns or claims for refund.
  18. § 28.6151-1 Time and place for paying tax shown on returns.
  19. § 28.6694-1 Section 6694 penalties applicable to return preparer.
  20. § 28.6694-2 Penalties for understatement due to an unreasonable position.
  21. § 28.6694-3 Penalty for understatement due to willful, reckless, or intentional conduct.
  22. § 28.6694-4 Extension of period of collection when tax return preparer pays 15 percent of a penalty for understatement of taxpayer's liability and certain other procedural matters.
  23. § 28.6695-1 Other assessable penalties with respect to the preparation of tax returns for other persons.
  24. § 28.6696-1 Claims for credit or refund by tax return preparers and appraisers.
  25. § 28.7701-1 Tax return preparer.