Page:United States Statutes at Large Volume 90 Part 2.djvu/411

 PUBLIC LAW 94-455—OCT. 4, 1976

90 STAT. 1879

(2) The amendment made by subsection (c) shall apply to gifts 26 USC 1023 made after December 31, 1976. note. SEC. 2006. CERTAIN GENERATION-SKIPPING TRANSFERS. (a) IMPOSITION OF TAX.—Subtitle B (relating to estate and gift taxes) is amended by adding at the end thereof the following new chapter:

"CHAPTER IS—TAX ON CERTAIN GENERATION-SKIPPING TRANSFERS "SUBCHAPTER A. Tax imposed.

"SUBCHAPTER B. Definitions and special rules. "SUBCHAPTER C. Administration.

"Subchapter A—Tax Imposed "Sec. 2601. Tax imposed. "Sec. 2602. Amount of tax. "Sec. 2603. Liability for tax. "SEC. 2601. TAX IMPOSED.

26 USC 2601.

"A tax is hereby imposed on every generation-skipping transfer in the amount determined under section 2602. "SEC. 2602. AMOUNT OF TAX. 26 USC 2602. "(a) GENERAL RULE.—The amount of the tax imposed by section

2601 with respect to any transfer shall be the excess of— "(1) a tentative tax computed in accordance with the rate schedule set forth in section 2001(c) (as in effect on the date Ante, p. 1846. of transfer) on the sum of— "(A) the fair market value of the property transferred determined as of the date of transfer (or in the case of an election under subsection (d), as of the applicable valuation date prescribed by section 2032), "(B) the aggregate fair market value (determined for purposes of this chapter) of all prior transfers of the deemed transferor to which this chapter applied, "(C) the amount of the adjusted taxable gifts (within the meaning of section 2001(b)) made by the deemed transferor before this transfer, and "(D) if the deemed transferor has died at the same time as, or before, this transfer, the taxable estate of the deemed transferor, over "(2) a tentative tax (similarly computed) on the sum of the amounts determined under subparagraphs (B), (C), and (D) of paragraph (1). "(b) MULTIPLE SIMULTANEOUS TRANSFERS.—If two or more transfers which are taxable under section 2601 and which have the same deemed Supra. transferor occur by reason of the same event, the tax imposed by section 2601 on each such transfer shall be the amount which bears the same ratio to— "(1) the amount of the tax which would be imposed by section 2601 if the aggregate of such transfers were a single transfer, as "(2) the fair market value of the property transferred in such transfer bears to the aggregate fair market value of all property transferred in such transfers. "(c) DEDUCTIONS, CREDITS, ETC.—

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