Donor’s Tax is a tax on a donation or gift, and is imposed on the gratuitous transfer of property between two or more

persons who are living at the time of the transfer. It shall apply whether the transfer is in trust or otherwise, whether
the gift is direct or indirect and whether the property is real or personal, tangible or intangible.

The estate tax is imposed on the transfer of the decedent’s estate to his lawful heirs and beneficiaries
based on the fair market value of the net estate at the time of the decedent’s death. It is not a tax on
property. It is a tax imposed on the privilege of transmitting property upon the death of the owner. The
estate tax is based on the laws in force at the time of death notwithstanding the postponement of the
actual possession or enjoyment of the estate by the beneficiary.