To establish for certain employees of international organizations an estate tax credit equivalent to the limited marital deduction.

Summary: Amends the Internal Revenue Code to apply, with limitations, an estate tax credit equivalent to the limited marital deduction to a decedent in a case in which, as of the date of the decedent's death: (1) both the decedent and the surviving spouse were noncitizens of, and not lawful permanent residents of, the United States; and (2) either the decedent or his or her surviving spouse was a qualified international organization employee.  Defines a qualified international organization employee as a full-time employee of an international organization whose principal place of employment with such organization is in the United States.

SECTION 1. CREDIT EQUIVALENT TO LIMITED MARITAL DEDUCTION IN CASE OF 
              CERTAIN EMPLOYEES OF INTERNATIONAL ORGANIZATIONS.

    (a) In General.--Subchapter C of chapter 11 of the Internal Revenue 
Code of 1986 is amended by adding at the end the following new section:

``SEC. 2210. CREDIT EQUIVALENT TO LIMITED MARITAL DEDUCTION IN CASE OF 
              CERTAIN EMPLOYEES OF INTERNATIONAL ORGANIZATIONS.

    ``(a) General Rule.--In the case of a decedent to whom this section 
applies, the tax determined under section 2001(b) or 2101(b) (whichever 
is applicable) shall be reduced by the applicable marital transfer 
credit determined under subsection (c).
    ``(b) Decedents to Whom Section Applies.--This section shall apply 
to a decedent if--
            ``(1) as of the date of the decedent's death--
                    ``(A) both the decedent and the surviving spouse of 
                the decedent were not citizens of the United States and 
                not lawful permanent residents of the United States, 
                and
                    ``(B) either the decedent or the surviving spouse 
                of the decedent was a qualified international 
                organization employee, and
            ``(2) the executor of the decedent's estate waives the 
        benefits of section 2056(d)(2).
    ``(c) Applicable Marital Transfer Credit.--
            ``(1) Estates taxable under section 2001.--
                    ``(A) In general.--If the estate of the decedent is 
                taxable under section 2001, the applicable marital 
                transfer credit is the excess of--
                            ``(i) a tentative tax computed under 
                        section 2001(c) on the sum of the marital 
                        transfer amount plus $600,000, over
                            ``(ii) a tentative tax computed under 
                        section 2001(c) on $600,000.
                If the amount of the adjusted taxable gifts of the 
                decedent exceeds $600,000, the amount of such gifts 
                shall be substituted for `$600,000' in clauses (i) and 
                (ii).
                    ``(B) Limitation on marital transfer amount.--The 
                amount of the marital transfer amount taken into 
                account under subparagraph (A) shall not exceed the 
                lesser of--
                            ``(i) $600,000, or
                            ``(ii) the excess of the sum referred to in 
                        section 2001(b)(1) over $600,000.
            ``(2) Estates taxable under section 2101.--If the estate of 
        the decedent is taxable under section 2101, the applicable 
        marital transfer credit shall be determined under the 
        principles of paragraph (1) with the following modifications--
                    ``(A) the $600,000 amount set forth in subparagraph 
                (B)(i) shall be reduced by the deduction equivalent of 
                the unified credit, and
                    ``(B) the deduction equivalent of the unified 
                credit shall be substituted for `$600,000' each place 
                it appears in paragraph (1) other than subparagraph 
                (B)(i).
    ``(d) Spouse Becomes Citizen.--This section shall not apply in any 
case in which paragraph (1) of section 2056(d) does not apply by reason 
of paragraph (4) of such section.
    ``(e) Other Definitions.--For purposes of this section--
            ``(1) Qualified international organization employee.--The 
        term `qualified international organization employee' means any 
        full-time employee of an international organization whose 
        principal place of employment with such organization is in the 
        United States.
            ``(2) Marital transfer amount.--The term `marital transfer 
        amount' means the amount which would have been allowable as a 
        deduction under section 2056 or 2106(a)(3) (whichever is 
        applicable) if section 2056 were applied without regard to 
        subsection (d) thereof.
            ``(3) Adjusted taxable gifts.--The term `adjusted taxable 
        gifts' has the same meaning as when used in section 2001 or 
        2101, whichever is applicable.
            ``(4) Deduction equivalent of unified credit.--The term 
        `deduction equivalent of unified credit' means, with respect to 
        any estate taxable under section 2101, the amount on which the 
        tentative tax determined under section 2001(c) would equal the 
        unified credit allowed under section 2102(c).''
    (b) Clerical Amendment.--The table of sections for subchapter C of 
chapter 11 of such Code is amended by adding at the end the following 
new item:

                              ``Sec. 2210. Credit equivalent to limited 
                                        marital deduction in case of 
                                        certain employees of 
                                        international organizations.''
    (c) Effective Date.--The amendments made by this section shall 
apply to the estates of decedents dying after the date of the enactment 
of this Act.