# § 2104. Property within the United States
**(a)** **Stock in corporation** For purposes of this subchapter shares of stock owned and held by a nonresident not a citizen of the United States shall be deemed property within the United States only if issued by a domestic corporation.
**(b)** **Revocable transfers and transfers within 3 years of death** For purposes of this subchapter, any property of which the decedent has made a transfer, by trust or otherwise, within the meaning of sections 2035 to 2038, inclusive, shall be deemed to be situated in the United States, if so situated either at the time of the transfer or at the time of the decedent’s death.
**(c)** **Debt obligations** For purposes of this subchapter, debt obligations of—
owned and held by a nonresident not a citizen of the United States shall be deemed property within the United States. Deposits with a domestic branch of a foreign corporation, if such branch is engaged in the commercial banking business, shall, for purposes of this subchapter, be deemed property within the United States. This subsection shall not apply to a debt obligation to which section 2105(b) applies.
**(1)** a United States person, or
**(2)** the United States, a State or any political subdivision thereof, or the District of Columbia,
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**Source Credit**: (Aug. 16, 1954, ch. 736, 68A Stat. 397; Pub. L. 89–809, title I, § 108(c), Nov. 13, 1966, 80 Stat. 1572; Pub. L. 91–172, title IV, § 435(b), Dec. 30, 1969, 83 Stat. 625; Pub. L. 93–17, § 3(a)(1), Apr. 10, 1973, 87 Stat. 12; Pub. L. 93–625, § 9(b), Jan. 3, 1975, 88 Stat. 2116; Pub. L. 94–455, title XX, § 2001(c)(1)(L), Oct. 4, 1976, 90 Stat. 1853; Pub. L. 100–647, title I, § 1012(q)(11), Nov. 10, 1988, 102 Stat. 3525; Pub. L. 104–188, title I, § 1704(t)(38), Aug. 20, 1996, 110 Stat. 1889; Pub. L. 111–226, title II, § 217(c)(3), Aug. 10, 2010, 124 Stat. 2402; Pub. L. 113–295, div. A, title II, § 221(a)(98), Dec. 19, 2014, 128 Stat. 4051.)
## Editorial Notes
### Amendments
2014—Subsec. (c). substituted “Deposits” for “With respect to estates of decedents dying after , deposits” in concluding provisions.
2010—Subsec. (c). , in concluding provisions, struck out before period at end “or to a debt obligation of a domestic corporation if any interest on such obligation, were such interest received by the decedent at the time of his death, would be treated by reason of section 861(a)(1)(A) as income from sources without the United States”.
1996—Subsec. (c). substituted “section 861(a)(1)(A)” for “subparagraph (A), (C), or (D) of section 861(a)(1)” in concluding provisions.
1988—Subsec. (c). substituted “subparagraph (A), (C), or (D) of section 861(a)(1)” for “section 861(a)(1)(B), section 861(a)(1)(G), or section 861(a)(1)(H)”.
1976—Subsec. (b). substituted “and transfers within 3 years of death” for “and transfers in contemplation of death” after “Revocable transfers”.
1975—Subsec. (c). inserted reference to in last sentence.
1973—Subsec. (c). made subsec. (c) inapplicable to debt obligations where interest on such obligations is treated as income from sources without the United States by reason of .
1969—Subsec. (c). substituted “” for “” in provisions deeming deposit with a domestic branch of a foreign corporation if such branch is engaged in the commercial banking business to be property within the United States.
1966—Subsec. (c). added subsec. (c).
## Statutory Notes and Related Subsidiaries
### Effective Date of 2014 Amendment
Amendment by effective , subject to a savings provision, see , set out as a note under .
### Effective Date of 2010 Amendment
Amendment by applicable to taxable years beginning after , with certain exceptions, see , set out as a note under .
### Effective Date of 1988 Amendment
Amendment by effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, , to which such amendment relates, see , set out as a note under .
### Effective Date of 1976 Amendment
Amendment by not applicable to transfers made before , see , set out as a note under .
### Effective Date of 1975 Amendment
Amendment by applicable with respect to estates of decedents dying after , see , set out as a note under .
### Effective Date of 1973 Amendment
> “The amendment made by paragraph (1) [amending this section] shall apply with respect to estates of decedents dying after
>
> , except that in the case of the assumption of a debt obligation of a foreign corporation which is treated as issued under section 4912(c)(2) after
>
> , and before
>
> , the amendment made by paragraph (1) [amending this section] shall apply with respect to estates of decedents dying after
>
> .”
, , , provided that:
### Effective Date of 1966 Amendment
Amendment by applicable with respect to estates of decedents dying after , see , set out as a note under .
### Short Title of 1973 Amendment
> “This Act [enacting sections 4922 and 6689 of this title, amending this section and sections 4911, 4912, 4914, 4915, 4916, 4918, 4919, 4920, and 6611 of this title, and enacting provisions set out as notes under this section] may be cited as the ‘Interest Equalization Tax Extension Act of 1973’.”
, , , provided that: