- 26 - at 820, 1986-3 C.B. (Vol. 2) at 820, describing then-present law, under the heading “Overview”, the Committee understood the GST tax was imposed on a transfer from a trust which specifically provided for distributions to a generation at least two generations removed from the grantor. This viewpoint is reiterated in H. Rept. 99-426, at 821, 1986-3 C.B. (Vol. 2) at 821, under the heading “Generation assignment”, which states in pertinent part: “A generation-skipping trust is a trust having two or more generations of ‘beneficiaries’ who belong to generations which are ‘younger’ than the generation of the grantor of the trust.” Significantly, nothing in the committee reports suggests that, when Congress referred to “transfers under a trust”, it ever contemplated or considered a volitional generation-skipping transfer arising from the exercise of a general power of appointment as opposed to a specific transfer by the settlor to identified persons. Second, in H. Rept. 99-426, supra at 824, 1986-3 C.B. (Vol. 2) at 824, the Committee stated, under the heading “Reasons for Change”: The committee believes, as it stated when the generation-skipping transfer tax originally was enacted in 1976, that the purpose of the three transfer taxes (gift, estate, and generation-skipping) is not only to raise revenue, but also to do so in a manner that has as nearly as possible a uniform effect. This policy is best served when transfer tax consequences do not vary widely depending on whether property is transferred outright to immediately succeeding generations or is transferred in ways that skip generations. * * * The bill accomplishes the committee’s goal of simplifiedPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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