I am expecting to receive a gift from a non-US person (my father), and am trying to determine if he will be liable for US taxes (as donor of the gift). The gift will come from his personal account in the US. I can't figure out if this personal account is considered 'US Situs' for purpose of gift taxes (and falls under this: The gift tax applies only to the transfer of real property and tangible personal property situated in the United States at the time of the transfer). Below is reference to some relevant tax laws:
From: https://www.law.cornell.edu/cfr/text/26/25.2511-3
(i) In the case of gifts made on or after January 1, 1967, a debt obligation, including a bank deposit, the primary obligor of which is a United States person ...constitutes property situated within the United States.
