§ 2519. Dispositions of certain life estates

Legislative history

Reconstructed from this section’s Code source credit and amendment notes, resolved against the local Statutes at Large. Editorial notes are evidence, not the law that made the change.

1. 1981

   Economic Recovery Tax Act of 1981

   Pub. L. 97–34 title IV § 403(d)(3)(B)(i) · 95 Stat. 175

   Enacted · 26 U.S.C. § 2519

   Added Pub. L. 97–34, title IV, § 403(d)(3)(B)(i), Aug. 13, 1981, 95 Stat. 304

   Source evidence

   Code source credit
   Added Pub. L. 97–34, title IV, § 403(d)(3)(B)(i), Aug. 13, 1981, 95 Stat. 304

   Enacted provision · exact public law section
   (i) In general.— Subchapter B of chapter 11 (relating to transfers) is amended by adding at the end thereof the following new section: “SEC. 2519. DISPOSITIONS OF CERTAIN LIFE ESTATES. “(a) General Rule.— Any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of such property. “(b) Property To Which This Subsection Applies.— This section applies to any property if a deduction was allowed with respect to the transfer of such property to the donor— “(1) under section 2056 by reason of subsection (b)(7) thereof, or “(2) under section 2523 by reason of subsection (f) thereof.”

   Effective date note
   Amendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

2. 1983

   Pub. L. 97–448 § 104(a)(3)(B) · 96 Stat. 2365

   Inserted · 26 U.S.C. § 2519

   Pub. L. 97–448, § 104(a)(3)(B), amended directory language of Pub. L. 97–34, § 403(d)(3)(B)(i), to clarify that this section be inserted at end of subchapter B of chapter 12, rather than at end of subchapter B of chapter 11, and did not involve any change in text

   Source evidence

   Code amendment note
   Pub. L. 97–448, § 104(a)(3)(B), amended directory language of Pub. L. 97–34, § 403(d)(3)(B)(i), to clarify that this section be inserted at end of subchapter B of chapter 12, rather than at end of subchapter B of chapter 11, and did not involve any change in text.

   Enacted provision · exact public law section
   (B) Clauses (i) and (ii) of section 403(d)(3)(B) of the Economic 95 Stat. 301. Recovery Tax Act of 1981 are each amended by striking out “chapter 11” and inserting in lieu thereof “chapter 12”.

   Effective date note
   Amendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

3. 1983

   Pub. L. 97–448 § 104(a)(3)(A) · 96 Stat. 2365

   1. Substituted · 26 U.S.C. § 2519(a)

      Pub. L. 97–448, § 104(a)(3)(A), substituted “For purposes of this chapter and chapter 11, any disposition” for “Any disposition”

   2. Substituted · 26 U.S.C. § 2519(a)

      Pub. L. 97–448, § 104(a)(3)(A), substituted “treated as a transfer of all interests in such property other than the qualifying income interest” for “treated as a transfer of such property”

   Source evidence

   Code amendment note
   Subsec. (a). Pub. L. 97–448, § 104(a)(3)(A), substituted “For purposes of this chapter and chapter 11, any disposition” for “Any disposition” and “treated as a transfer of all interests in such property other than the qualifying income interest” for “treated as a transfer of such property”.

   Enacted provision · exact public law section
   (A) 26 USC 2519. Subsection (a) of section 2519 (relating to dispositions of certain life estates) is amended to read as follows: “(a) General Rule.— For purposes of this chapter and chapter 11, any disposition of all or part of a qualifying income interest for life in any property to which this section applies shall be treated as a transfer of all interests in such property other than the qualifying income interest.”

   Effective date note
   Amendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

4. 1983

   Pub. L. 97–448 § 104(a)(7) · 96 Stat. 2365

   Added · 26 U.S.C. § 2519(c)

   Pub. L. 97–448, § 104(a)(7), added subsec. (c)

   Source evidence

   Code amendment note
   Subsec. (c). Pub. L. 97–448, § 104(a)(7), added subsec. (c).

   Enacted provision · exact public law section
   (7) Cross reference.— Section 2519 is amended by adding at 26 USC 2519. the end thereof the following new subsection: “(c) Cross Reference.— “For right of recovery for gift tax in the case of property treated as transferred under this section, see section 2207A(b).”

   Effective date note
   Amendment by Pub. L. 97–448 effective, except as otherwise provided, as if it had been included in the provision of the Economic Recovery Tax Act of 1981, Pub. L. 97–34, to which such amendment relates, see section 109 of Pub. L. 97–448, set out as a note under section 1 of this title.

5 of 5 references resolved to an enrolled provision