To amend the Internal Revenue Code of 1986 with respect to treatment of estate freezes.

Repeals estate tax provisions of the Internal Revenue Code with respect to inclusion in the gross estate of the value of certain types of transfers with a retained life estate.

Applies the repeal retroactively in connection with property transferred after December 17, 1987.

Establishes special valuation rules for determining whether a transfer of an interest in a corporation or partnership which is ten-percent owned to a member of the transferor's family is a gift. Provides for determining the valuation of any retained interests and qualified payments under such interests. Provides that where qualified payments are not made before the close of the third calendar year following the calendar year in which such payment was due, they shall be treated as a transfer of property by gift.

Provides for the valuation of the transfer of property by gift if the transferor transfers any qualified retained interest or the transferor dies.

Sets forth rules for adjustments in the case of transfers of nonqualified retained interests or where a corporation becomes insolvent.

Sets forth valuation rules for determining whether a transfer of an interest in a trust to a member of the transferor's family is a gift.

Provides for determining the value of any property without regard to the following rights with respect to such property held by a member of the family of the transferor or decedent: (1) any option or agreement to acquire the property at a price less than the fair market value as of the time the option is exercised; (2) any right of first refusal; and (3) any right to use such property pursuant to a lease.

Sets forth rules governing the transfer tax consequences of lapsing rights and restrictions.

Provides for the treatment of indirect holdings, certain redemptions, and creditor and lessor interests.

Declares that a gift tax may be assessed on any gift of property under this Act at any time if it is not shown on the tax return although it is required to be.