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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retroactively repealed the 1976 provisions and enacted new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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