26 U.S.C. § 2653
Taxation of multiple skips
United States · Title 26 — INTERNAL REVENUE CODE · Status: effective
Cite this
- Citation
- 26 U.S.C. § 2653, Taxation of multiple skips, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/463259
- Permanent ID
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26a00341bafb4edb897f3af3b9f7372910ae94028b607b0f77027368ba46300f
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Full text
For purposes of this chapter, if—
Except as provided in paragraph (2), the provisions of subsection (a) shall not affect the inclusion ratio determined with respect to any trust. Under regulations prescribed by the Secretary, notwithstanding the preceding sentence, proper adjustment shall be made to the inclusion ratio with respect to such trust to take into account any tax under this chapter borne by such trust which is imposed by this chapter on the transfer described in subsection (a).
If the generation-skipping transfer referred to in subsection (a) involves the transfer of property from 1 trust to another trust (hereinafter in this paragraph referred to as the “pour-over trust”), the inclusion ratio for the pour-over trust shall be determined by treating the nontax portion of such distribution as if it were a part of a GST exemption allocated to such trust.
For purposes of subparagraph (A), the nontax portion of any distribution is the amount of such distribution multiplied by the applicable fraction which applies to such distribution.
Legislative history
The public laws that enacted or amended this section. Tallies are for the whole bill as it passed each chamber — often an omnibus covering far more than this provision — not a vote on this section alone.
- Tax Reform Act of 1986House: no recorded tallySenate: no recorded tally