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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 simplified
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