Page:United States Statutes at Large Volume 115 Part 1.djvu/108

 115 STAT. 86 PUBLIC LAW 107-16—JUNE 7, 2001 (6) CLERICAL AMENDMENT.—The table of sections for part II of subchapter O of chapter 1 is amended by inserting after the item relating to section 1021 the following new item: "Sec. 1022. Treatment of property acquired from a decedent dying after December 31, 2009.". Applicability. (f) EFFECTIVE DATE. — 26 USC 121 note. (1) IN GENERAL.— Except as provided in paragraph (2), the amendments made by this section shall apply to estates of decedents dying after December 31, 2009. (2) TRANSFERS TO NONRESIDENTS.—The amendments made by subsection (e)(1) shall apply to transfers after December 31, 2009. (3) SECTION 4947. —The amendment made by subsection (e)(4) shall apply to deductions for taxable years beginning after December 31, 2009. 26 USC 2031. Applicability. 26 USC 2031 note. Subtitle F—Conservation Easements SEC. 551. EXPANSION OF ESTATE TAX RULE FOR CONSERVATION EASE- MENTS. (a) REPEAL OF CERTAIN RESTRICTIONS ON WHERE LAND IS LOCATED.— Clause (i) of section 2031(c)(8)(A) (defining land subject to a qualified conservation easement) is amended to read as follows: "(i) which is located in the United States or any possession of the United States,". (b) CLARIFICATION OF DATE FOR DETERMINING VALUE OF LAND AND EASEMENT. — Section 2031(c)(2) (defining applicable percentage) is amended by adding at the end the following new sentence: "The values taken into account under the preceding sentence shall be such values as of the date of the contribution referred to in paragraph (8)(B).". (c) EFFECTIVE DATE. —The amendments made by this section shall apply to estates of decedents dying after December 31, 2000. Subtitle G—Modifications of Generation- Skipping Transfer Tax SEC 561. DEEMED ALLOCATION OF GST EXEMPTION TO LIFETIME TRANSFERS TO TRUSTS; RETROACTIVE ALLOCATIONS. (a) IN GENERAL.— Section 2632 (relating to special rules for allocation of GST exemption) is amended by redesignating subsection (c) as subsection (e) and by inserting after subsection (b) the following new subsections: " (c) DEEMED ALLOCATION TO CERTAIN LIFETIME TRANSFERS TO GST TRUSTS.— "(1) IN GENERAL. — If any individual makes an indirect skip during such individual's lifetime, any unused portion of such individual's GST exemption shall be allocated to the property transferred to the extent necessary to make the inclusion ratio for such property zero. If the amount of the indirect skip exceeds such unused portion, the entire unused portion shall be allocated to the property transferred.

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