Page:United States Statutes at Large Volume 100 Part 3.djvu/910

 100 STAT. 2718

PUBLIC LAW 99-514—OCT. 22, 1986 "Subchapter A—Tax Imposed "Sec. "Sec. "Sec. "Sec.

2601. Tax imposed. 2602. Amount of tax. 2603. Liability for tax. 2604. Credit for certain State taxes.

"SEC. 2601. TAX IMPOSED.

"A tax is hereby imposed on every generation-skipping transfer (within the meaning of subchapter B). "SEC. 2602. AMOUNT OF TAX.

"The amount of the tax imposed by section 2601 is— "(1) the taxable amount (determined under subchapter C), multiplied by "(2) the applicable rate (determined under subchapter E). "SEC. 2603. LIABILITY FOR TAX. "(a) PERSONAL LIABILITY.— "(1) TAXABLE DISTRIBUTIONS.—In the case of a taxable dis-

tribution, the tax imposed by section 2601 shall be paid by the transferee. "(2) TAXABLE TERMINATION.—In the case of a taxable termination or a direct skip from a trust, the tax shall be paid by the trustee. "(3) DIRECT SKIP.—In the case of a direct skip (other than a direct skip from a trust), the tax shall be paid by the transferor. "0)) SOURCE OF TAX.—Unless otherwise directed pursuant to the governing instrument by specific reference to the tax imposed by this chapter, the tax imposed by this chapter on a generationskipping transfer shall be charged to the property constituting such transfer. "(c) CROSS REFERENCE.— "For provisions making estate and gift tax provisions with respect to transferee liability, liens, and related matters applicable to the tax imposed by section 2601, see section 2661. "SEC. 2604. CREDIT FOR CERTAIN STATE TAXES.

"(a) GENERAL RULE.—If a generation-skipping transfer (other than a direct skip) occurs at the same time as and as a result of the death of an individual, a credit against the tax imposed by section 2601 shall be allowed in an amount equal to the generation-skipping transfer tax actually paid to any State in respect to any property included in the generation-skipping transfer. "(b) LIMITATION.—The aggregate amount allowed as a credit under this section with respect to any transfer shall not exceed 5 percent of the amount of the tax imposed by section 2601 on such transfer.

"Subchapter B—Generation-Skipping Transfers "Sec. 2611. Generation-skipping transfer defined. "Sec. 2612. Taxable termination; taxable distribution; direct skip. "Sec. 2613. Skip person and non-skip person defined. "SEC. 2611. GENERATION-SKIPPING TRANSFER DEFINED.

"(a) IN GENERAL.—For purposes of this chapter, the term 'generation-skipping transfers' mean— "(1) a taxable distribution.

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