1. Property left by the deceased who was an ROC citizen and resided in the ROC continuously shall be subject to the levy of estate tax, notwithstanding whether the location of the property is within or outside of ROC.

2. Property left by the deceased who was an ROC citizen and did not resided in the ROC continuously or who was a non-ROC citizen shall be subject to the levy of estate tax only to the extent that it is located within the ROC.

1. Executor of the will

2. Heir(s) or legatee(s), in case that no executor is appointed.

3. An administrator elected pursuant to the law, in the case of non-existence of heir(s) or executor of the will.

1. Estate and Gift Tax Act

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