A Person is not a US Person but maintains a bank account in the US when the person was a tourist in the US. This person does not work in the US nor ever stay in the US for more than 10 days in a year. The funding source for that bank account is from his own personal bank account in his home country (so the money is not made in the US).
If he chooses to gift the money sitting in the US bank account, say $100,000 to a US personal, would he have to pay any gift tax? Assuming that his original home country doesn't have any gift tax.