To amend the Internal Revenue Code of 1986 to restore the estate tax and repeal the carryover basis rule, to increase the estate and gift tax unified credit to an exclusion equivalent of $5,000,000, and to reduce the rate of the estate and gifts taxes to the generally applicable capital gains income tax rate.

Repeals subtitles A (Repeal of Estate and Generation-Skipping Transfer Taxes) and E (Carryover Basis at Death; Other Changes Taking Effect With Repeal) of title V (Estate, Gift, and Generation-Skipping Transfer Tax Provisions) of the Economic Growth and Tax Relief Reconciliation Act of 2001. Makes the sunset provisions of such Act inapplicable to the remainder of title V.

Reduces estate and gift tax rates to the lesser of 15 percent or the applicable capital gains rate.

Sets a unified estate and gift tax credit of $5 million.