PUBLIC LAW 94-455—OCT. 4, 1976 "(d)
90 STAT. 1851
RATE SCHEDULE.—
"If the amount with respect to which the tentative tax to be computed is: The tentative tax is: Not over $100,000 6% of such amount. Over $100,000 but not over $500,000 $6,000, plus 12% of $100,000. Over $500,000 but not over $1,000,000__. $54,000, plus 18% of $500,000. Over $1,000,000 but not over $2,000,000- $144,000, plus 24% of $1,000,000. Over 2,000,000 $384,000, plus 30% of $2,000,000."
excess over excess over excess over
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excess over
(E) CREDIT I N CASE OF ESTATE OF NONRESIDENTS NOT CITIZENS.—
(i) Section 2102 (relating to credits against tax i n 26 USC 2102. case of estates of nonresidents not citizens) is amended by a d d i n g a t the end thereof the following new subsection:
- ' (c) U N I F I E D C R E D I T. —
" (1) IN GENERAL.—A credit of $3,600 shall be allowed against the tax imposed by section 2101.
Ante, p. 1850.
" (2) RESIDENTS OF POSSESSIONS o r THE UNITED STATES.—In the
case of a decedent who is considered to be a 'nonresident not a citizen of the United States' under section 2209, the credit under this subsection shall be the greater of— " (A) $3,600, o r " (B) that proportion of $15,075 which the value of that part of the decedent's gross estate which a t the time of his death is situated in the United States bears to the value of his entire gross estate wherever situated. " (3) P H A S E - I N OF PARAGRAPH (2)(B) A M O U N T. — I n the case of
i
a decedent d y i n g before 1981, paragraph (2)(B) shall be applied— " (A) in the case of a decedent dying during 1977, by substituting '$8,480' for '$15,075', " (B) in the case of a decedent dying during 1978, by substituting '$10,080' for '$15,075', " (C) in the case of a decedent dying during 1979, by substituting '$11,680' for '$15,075', and " (D) in the case of a decedent dying during 1980, by substituting '$13,388' for '$15,075'. " (4) L I M I T A T I O N BASED ON AMOUNT OF TAX.—The credit allowed
under this subsection shall not exceed the amount of the tax imposed by section 2101. " (5) APPLICATION OF OTHER CREDITS.—For purposes of subsec-
tion (a), sections 2011 to 2013, inclusive, shall be applied as if the credit allowed under this subsection were allowed under section 2010." (ii) Subsection (c) of section 2107 (relating to expatriation to avoid tax) is amended to read as follows: "(c)
26 USC 2107.
CREDITS.— " (1) U N I F I E D CREDIT.—
" (A) IN GENERAL.—^A credit of $13,000 shall be allowed against the tax imposed by subsection (a). "(B)
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L I M I T A T I O N BASED ON AMOUNT OF TAX.—The credit
allowed under this paragraph shall not exceed the amount of the tax imposed by subsection (a). " (2) OTHER CREDITS.—The tax imposed by subsection (a) shall
be credited with the amounts determined in accordance with sub-
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