Gift Tax Consequences Between Spouses of Different Citizenships: A Comparative Analysis Under American and Brazilian Law.

The article presents the analysis of gifting strategies and gift tax consequences for gifts made between American and Brazilian spouses. Topics discussed include regulation of gift tax by the Internal Revenue Code on transfer of property based on the cumulative amount of taxable gifts, application of the gift tax depending on the nature of transfer of real property, and provision for medical and educational exclusion to gifts by U.S. citizens through qualified transfers.