26 C.F.R. § 1.1491-1 Imposition of tax.
Title 26 - Internal Revenue
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 [T.D. 6500, 25 FR 12082, Nov. 26, 1960]
Title 26: Internal Revenue
PART 1—INCOME TAXES
Tax on Transfers To Avoid Income Tax
§ 1.1491-1 Imposition of tax.