Estate of Milada S. Neumann, Deceased, Eric W. Shaw, Ancillary Administrator, C.T.A. - Page 4

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            "direct skip" transfers such as are involved herein, e.g.,                                 
            outright bequests by a decedent to a grandchild.  See Staff of                             
            Joint Comm. on Taxation, General Explanation of the Tax Reform                             
            Act of 1976, at 565 (J. Comm. Print 1976), 1976-3 C.B. (Vol. 2)                            
            577.  Section 2614(b), enacted in 1976, made clear that the GST                            
            tax was to apply only to nonresident aliens in respect of                                  
            property that would otherwise be taken into account for purposes                           
            of the estate tax to which nonresident aliens were already                                 
            subject by virtue of section 2101(a).  See General Explanation of                          
            the Tax Reform Act of 1976, supra at 580, 1976-3 C.B. (Vol. 2) at                          
            592.                                                                                       
                  In 1986, dissatisfied with the GST tax, Congress                                     
            retroactively repealed the 1976 provisions and enacted new                                 
            provisions extending the GST tax to "direct skip" transfers such                           
            as are involved herein.  See Tax Reform Act of 1986, Pub. L. 99-                           
            514, sec. 1431, 100 Stat. 2085, 2717.2   Section 2663, enacted in                          
            1986, provided:                                                                            
                        The Secretary shall prescribe such regulations as                              
                  may be necessary or appropriate to carry out the                                     
                  purposes of this chapter, including--                                                
                                    *   *   *   *   *   *   *                                          
                              (2)  regulations (consistent with the                                    
                        principles of chapters 11 and 12) providing for                                

            2  Sec. 2614(b) disappeared in the 1986 amendments presumably                              
            because Congress intended the limitation to be reflected in the                            
            definitions in sec. 2612.                                                                  




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