[Code of Federal Regulations]
[Title 26, Volume 12]
[Revised as of April 1, 2004]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR1.1491-1]

[Page 236]
 
                       TITLE 26--INTERNAL REVENUE
 
    CHAPTER I--INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY 
                               (CONTINUED)
 
PART 1_INCOME TAXES--Table of Contents
 
Sec. 1.1491-1  Imposition of tax.

    Section 1491 imposes an excise tax upon transfers of stock or 
securities by a citizen or resident of the United States, or by a 
domestic corporation or partnership, or by a trust which is not a 
foreign trust, to a foreign corporation as paid-in surplus or as a 
contribution to capital, or to a foreign trust, or to a foreign 
partnership. The tax is in an amount equal to 27\1/2\ percent of the 
excess of (a) the value of the stock or securities so transferred over 
(b) its adjusted basis, as provided in section 1011, for determining 
gain in the hands of the transferor.

[T.D. 6500, 25 FR 12082, Nov. 26, 1960]