Page:United States Statutes at Large Volume 100 Part 3.djvu/912

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PUBLIC LAW 99-000—MMMM. DD, 1986

100 STAT. 2720

PUBLIC LAW 99-514—OCT. 22, 1986 such individual shall be treated as if such individual were a child of the transferor and all of that grandchild's children shall be treated as if they were grandchildren of the transferor. In the case of lineal descendants below a grandchild, the preceding sentence may be reapplied.

"SEC. 2613. SKIP PERSON AND NONSKIP PERSON DEFINED.

"(a) SKIP PERSON.—For purposes of this chapter, the term 'skip person' means— "(1) a person assigned to a generation which is 2 or more generations below the generation assignment of the transferor, or "(2) a trust— "(A) if all interests in such trust are held by skip persons, or "(B) if— "(i) there is no person holding an interest in such trust, and "(ii) at no time after such transfer may a distribution (including distributions on termination) be made from such trust to a nonskip person. "(b) NON-SKIP PERSON.—For purposes of this chapter, the term 'non-skip person' means any person who is not a skip person.

"Subchapter C—Taxable Amount "Sec. "Sec. "Sec. "Sec.

2621. Taxable amount in case of taxable distribution. 2622. Taxable amount in case of taxable termination. 2623. Taxable amount in case of direct skip. 2624. Valuation.

"SEC. 2621. TAXABLE AMOUNT IN CASE OF TAXABLE DISTRIBUTION.

"(a) IN GENERAL.—For purposes of this chapter, the taxable amount in the case of any taxable distribution shall be— "(1) the value of the property received by the transferee, reduced by "(2) any expense incurred by the transferee in connection with the determination, collection, or refund of the tax imposed by this chapter with respect to such distribution. "(b) PAYMENT OF GST TAX TREATED AS TAXABLE DISTRIBUTION.—

For purposes of this chapter, if any of the tax imposed by this chapter with respect to any taxable distribution is paid out of the trust, an amount equal to the portion so paid shall be treated as a taxable distribution. "SEC. 2622. TAXABLE AMOUNT IN CASE OF TAXABLE TERMINATION.

"(a) IN GENERAL.—For purposes of this chapter, the taxable amount in the case of a taxable termination shall be— "(1) the value of all property with respect to which the taxable termination has occurred, reduced by "(2) any deduction allowed under subsection (b). "(b) DEDUCTION FOR CERTAIN EXPENSES.—For purposes of subsection (a), there shall be allowed a deduction similar to the deduction allowed by section 2053 (relating to expenses, indebtedness, and taxes) for amounts attributable to the property with respect to which the taxable termination has occurred.