PUBLIC LAW 94-455—OCT. 4, 1976
9 0 STAT. 184.9
ber 31, 1976, and during the 3-year period e n d i n g on the date of the decedent's death." (b) CHANGES I N G I F T T A X. —
(1) E A T E OF TAX.—Subsection (a) of section 2502 (relating 26 USC 2502. to rate of gift tax) is amended to read as follows: " (a) COMPUTATION OF T A X. — The tax imposed by section 2501 for each calendar quarter shall be an amount equal to the excess of— " (1) a tentative tax, computed i n accordance with the rate schedule set forth in section 2001(c), on the aggregate sum of Ante, p. 1846. the taxable gifts for such calendar quarter and for each of the preceding calendar years and calendar quarters, over " (2) a tentative tax, computed i n accordance w i t h such r a t e schedule, on the aggregate sum of the taxable gifts for each of the preceding calendar years and calendar quarters." (2) U N I F I E D CREDIT.—Subchapter A of chapter 12 (relating
to determination of gift tax liability) is amended by a d d i n g a t the end thereof the following new section: "SEC. 2505. UNIFIED CREDIT AGAINST GIFT TAX. 25 USC 2505. " (a) GENERAL RULE. — I n the case of a citizen or resident of the United States, there shall be allowed as a credit against the tax imposed by section 2501 for each calendar quarter an amount equal to— " (1) $47,000, reduced by " (2) the sum of the amounts allowable as a credit to the individual under this section for all preceding calendar quarters. " (b) P H A S E - I N OF $47,000 CREDIT.—
Subsection (a)(1) shall be applied by substituting for '$47,000' the follow"In the case of gifts made: ing amount: After December 31, 1976, and before July 1, 1977 $6,000 After June 30, 1977, and before January 1, 1978 $30,000 After December 31, 1977, and before January 1, 1979 $34, 000 After December 31, 1978, and before January 1, 1980 $38,000 After December 31, 1979, and before January 1, 1981 $42, 500 "(c)
ADJUSTMENT
TO CREDIT FOR CERTAIN
G I F T S MADE
•.. -
BEFORE
1977.—The amount allowable under subsection (a) shall be reduced by an amount equal to 20 percent of the aggregate amount allowed as a specific exemption under section 2521 ( a s i n effect before i t s repeal by the T a x Reform Act of 1976) with respect to gifts made by the individual after September 8, 1976. "(d)
L I M I T A T I O N BASED ON A M O U N T OF T A X. — The a m o u n t of the
credit allowed under subsection (a) for any calendar quarter shall not exceed the amount of the tax imposed by section 2501 for such calendar quarter." (3) REPEAL OF SPECIFIC EXEMPTION.—Section 2521 ( r e l a t i n g to
26 USC 2521.
specific exemption in the case of the gift tax) is hereby repealed. (c) T E C H N I C A L, CLERICAL, AND CONFORMING C H A N G E S. — (1) CHANGES I N ESTATE TAX.— (A) CREDIT FOR STATE DEATH TAXES.—Section 2011 (relat-
'
ing to credit for State death taxes) is amended— (i) by striking out "taxable estate" each place i t appears i n subsection (b) (including the heading to the table) and inserting i n lieu thereof "adjusted taxable estate"; (ii) by a d d i n g a t the end of subsection (b) the following new sentence:
26 USC 2011.
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