Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 56-52

1956-1 C.B. 448

Full Text

Rev. Rul. 56-52

An ambassador, or other diplomatic officer of a foreign country, duly accredited to the United States, is not considered, for estate tax purposes, as having been engaged in business in the United States at the time of his death solely by reason of his activities in this country in connection with the formal representation of his government as an accredited diplomat. Consequently, any moneys deposited with any person carrying on the banking business by or for the ambassador, or other diplomatic officer of a foreign country, who at the time of his death is neither domiciled in nor a national of the United States, and obligations of the United States issued prior to March 1, 1941, owned by such person, are exempt from the Federal estate tax under the provisions of sections 2105(b) and 2106(c), respectively, of the Internal Revenue Code of 1954, provided he is not otherwise engaged in business in the United States at the time of his death. Compare Revenue Ruling 187, C.B. 1953-2, 291, which held that the estate tax is not applicable to personal property used by a foreign envoy duly accredited to the United States in the conduct of his official mission and reasonably required for such purpose. This ruling is not to be construed as having any effect upon a determination of the trade or business of an ambassador or other diplomatic officer of a foreign country for Federal income tax purposes. See section 871 of the Code.