1. Any gift made by a donor who is an ROC citizen and resides in the ROC continuously shall be subject to gift taxation irrespective of whether the property given away is located within or outside the ROC.

2. A gift made by a donor who is an ROC citizen but resides outside the ROC continuously or who is a non-ROC citizen shall be subject to gift taxation only to the extent that the property given away is located in the ROC.

1. Estate and Gift Tax Act

2. The Enforcement Rules of the Estate and Gift Tax Act