A bill to repeal the existing generation-skipping tax and to substitute therefor a tax on distributions from (and certain terminations of interest in) generation-skipping trusts and a tax on outright skips.
GST Tax Simplification Act of 1984 - Amends the Internal Revenue Code to impose a separate tax on three forms of generation-skipping transfers: (1) taxable distributions; (2) taxable terminations; and (3) outright skips. Provides that the rate of tax on these generation-skipping transfers will be equal to the maximum unified Federal estate and gift tax rate. Allows every transferor to take a credit of $417,000 against the generation-skipping transfers during the transferor's life. Sets forth rules for the allocation of such credit. Defines "taxable distribution," "taxable termination," and "outright skips" for purposes of this Act.
Levies a gift tax on taxable distributions. Provides that the trustee making the distribution is liable for the payment of the tax. Permits the distributee to elect to pay the tax. Denies the taxable distribution eligibility for the annual gift tax exclusion. Permits an income tax deduction for a percentage of the taxable distribution includible in the gross income of the distributee.
Imposes a surtax on every outright generation skip. Makes the transferor liable for the payment of this tax.
Imposes an estate tax on every taxable termination. Provides that the trustee with respect to which the taxable termination occurs shall be liable for the payment of the tax.
Provides special rules and definitions relating to the operation of the generation skipping transfer taxes.
Directs the Secretary of the Treasury to prescribe by regulations the person required to make the return with respect to the generation-skipping transfer tax and the time for making such return. Requires the Secretary to promulgate regulations to implement the generation-skipping transfer taxes.
Introduced in House
Introduced in House
Referred to House Committee on Ways and Means.
Committee Hearings Held.
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