The South Carolina estate tax, S.C. Code Ann.§ 12-16-10 et seq, imposes a tax on the transfer of the estate of both residents and nonresidents. Id., § 12-16-510, 520. (The South Carolina Estate Tax Act also imposes a tax on the transfer of the estate of aliens and includes a generation-skipping transfer tax. This article does not address these issues.) On its face, the tax appears straightforward and, in effect, represents a relatively fair death tax approach. Nevertheless, it contains unexpected nuances.
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