Description of Generation-skipping Transfer Tax Simplification Proposals (H.R. 6260 and H.R. 6261) and Background Information: Scheduled for a Hearing Before the Committee on Ways and Means, on October 2, 1984

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Page 8 - ... for 5 of the last 8 years prior to the decedent's death ; and (6) there must have been material participation in the operation of the farm or closely held business by the decedent or a member of his family in 5 years out of the 8 years immediately preceding the decedent's death (Code sees.
Page 9 - The tax imposed by subdivision (a) of this section shall be credited with the amount of any estate, inheritance, legacy, or succession taxes actually paid to any State or Territory or the District of Columbia, in respect of any property included in the gross estate (not including any such taxes paid with respect to the estate of a person other than the decedent).
Page 12 - ... and the basis of the property in the hands of the trustee would be its fair market value on the date of the decedent's death or on the alternate valuation date.
Page 7 - Joint interests. (a) In general. A decedent's gross estate includes under section 2040 the value of property held jointly at the time of the decedent's death by the decedent and another person or persons with right of survivorship, as follows: (1) To the extent that the property was acquired by the decedent and the other joint owner or owners by gift, devise, bequest, or inheritance, the decedent's fractional share of the property is included. (2) In all other cases, the entire value of the property...
Page 7 - ... the value of the farm or closely held business assets in the decedent's estate, including both real and personal property...
Page 3 - Act, a tax is imposed in the case of generation-skipping transfers under a trust or similar arrangement upon the distribution of the trust assets to a generationskipping heir (for example, a...
Page 21 - A taxable termination means the termination of an interest or power of a younger generation beneficiary who is a member of a generation which is older than that of any other younger generation beneficiary. Such a termination would generally occur by reason of death (in the case of a life interest) or by lapse of time (in a case where the grantor created an estate for years) . For example, if a trust provided income for life to the grantor's child, with remainder to the grantor's...
Page 24 - The conference agreement provides that the alternate valuation date is to be available where a taxable termination occurs at the death of the deemed transferor. In this case the election to use the alternate valuation date is to be made by the trustee of the generation-skipping trust (who is also the- person liable for the tax under these circumstances) and it is not required that the executor of the deemed transferor's estate also elect the alternate valuation date (since different persons are liable...
Page 7 - ... which is shown not to be attributable to money or other property acquired by the other joint owner or owners from the decedent for less than a full and adequate consideration in money or money's worth.
Page 10 - ... grandchild). Basically, a generation-skipping trust is one which provides for a splitting of the benefits between two or more generations which are younger than the generation of the grantor of the trust. The generation-skipping tax is not imposed in the case of outright transfers.

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