110 STAT. 2098 PUBLIC LAW 104-191—AUG. 21, 1996 ance, legacy, or succession taxes actually paid to any foreign country in respect of any property which is included in the gross estate solely by reason of subsection (b). "(B) LIMITATION ON CREDIT. —The credit allowed by subparagraph (A) for such taxes paid to a foreign country shall not exceed the lesser of— "(i) the amount which bears the same ratio to the amount of such taxes actually paid to such foreign country in respect of property included in the gross estate as the value of the property included in the gross estate solely by reason of subsection (b) bears to the value of all property subjected to such taxes by such foreign country, or "(ii) such property's proportionate share of the excess of— "(I) the tax imposed by subsection (a), over "(II) the tax which would be imposed by section 2101 but for this section. "(C) PROPORTIONATE SHARE. —For purposes of subparagraph (B), a property's proportionate share is the percentage of the value of the property which is included in the gross estate solely by reason of subsection (b) bears to the total value of the gross estate.". (C) EXPANSION OF INCLUSION IN GROSS ESTATE OF STOCK OF FOREIGN CORPORATIONS. —Paragraph (2) of section 2107(b) is amended by striking "more than 50 percent of" and all that follows and inserting "more than 50 percent of— "(A) the total combined voting power of all classes of stock entitled to vote of such corporation, or "(B) the total value of the stock of such corporation,". (2) GIFT TAX. — (A) IN GENERAL. —Paragraph (3) of section 2501(a) is amended to read as follows: "(3) EXCEPTION. — "(A) CERTAIN INDIVIDUALS.— Paragraph (2) shall not apply in the case of a donor who, within the 10-year period ending with the date of transfer, lost United States citizenship, unless such loss did not have for one of its principal purposes the avoidance of taxes under this subtitle or subtitle A. " (B) CERTAIN INDIVIDUALS TREATED AS HAVING TAX AVOIDANCE PURPOSE.— For purposes of subparagraph (A), an individual shall be treated as having a principal purpose to avoid such taxes if such individual is so treated under section 877(a)(2). "(C) EXCEPTION FOR CERTAIN INDIVIDUALS. — Subparagraph (B) shall not apply to a decedent meeting the requirements of section 877(c)(1). "(D) CREDIT FOR FOREIGN GIFT TAXES.— The tax imposed by this section solely by reason of this paragraph shall be credited with the amount of any gift tax actually paid to any foreign country in respect of any gift which is taxable under this section solely by reason of this paragraph. ". (f) COMPARABLE TREATMENT OF LAWFUL PERMANENT RESIDENTS WHO CEASE TO BE TAXED AS RESIDENTS.—
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