I 

117TH CONGRESS 

1ST SESSION H. R. 2576 

To amend the Internal Revenue Code of 1986 to reinstate estate and 

generation-skipping taxes, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

APRIL 15, 2021 

Mr. GOMEZ (for himself, Mr. BLUMENAUER, Ms. BUSH, Mr. CARSON, Ms. 

CHU, Mr. COHEN, Mr. DANNY K. DAVIS of Illinois, Mr. DEFAZIO, Ms. 

DELAURO, Mr. DESAULNIER, Mr. ESPAILLAT, Mr. GARCI ́A of Illinois, 

Mr. GRIJALVA, Ms. NORTON, Ms. JAYAPAL, Mr. JONES, Mr. KHANNA, 

Ms. LEE of California, Mr. LEVIN of Michigan, Mr. LIEU, Mr. 

LOWENTHAL, Mrs. CAROLYN B. MALONEY of New York, Ms. MENG, Mrs. 

NAPOLITANO, Ms. NEWMAN, Ms. OMAR, Mr. PAYNE, Mr. POCAN, Ms. 

PRESSLEY, Ms. ROYBAL-ALLARD, Mr. RUSH, Ms. SCHAKOWSKY, Mr. 

TAKANO, Ms. TLAIB, and Mrs. WATSON COLEMAN) introduced the following bill; which was referred to the Committee on Ways and Means 

A BILL 

To amend the Internal Revenue Code of 1986 to reinstate 

estate and generation-skipping taxes, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘For the 99.5 Percent 

5 Act’’. 


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1 SEC. 2. MODIFICATIONS TO ESTATE, GIFT, AND GENERA2 TION-SKIPPING TRANSFER TAXES. 

3 (a) MODIFICATION OF RATES.—Section 2001(c) of 

4 the Internal Revenue Code of 1986 is amended by striking 

5 the last 2 rows and inserting the following: 

‘‘Over $750,000 but not over $3,500,000 ............. $248,300 plus 39 percent of the excess of 

such amount over 

$750,000. 

Over $3,500,000 but not over $10,000,000 ........ $1,320,800 plus 45 

percent of the excess of such amount 

over $3,500,000. 

Over $10,000,000 but not over $50,000,000 ...... $4,245,800 plus 50 

percent of the excess of such amount 

over $10,000,000. 

Over $50,000,000 but not over $1,000,000,000 $24,245,800 plus 55 

percent of the excess of such amount 

over $50,000,000. 

Over $1,000,000,000 ............................................. $546,745,800 plus 65 

percent of the excess of such amount 

over 

$1,000,000,000.’’. 

6 (b) EXCLUSION AMOUNT.— 

7 (1) ESTATE TAX.—Paragraph (3) of section 

8 2010(c) of the Internal Revenue Code of 1986 is 

9 amended to read as follows: 

10 ‘‘(3) BASIC EXCLUSION AMOUNT.—For pur11 poses of this section, the basic exclusion amount is 

12 $3,500,000.’’. 

13 (2) MODIFICATION TO GIFT TAX EXCLUSION

14 AMOUNT.—Paragraph (1) of section 2505(a) of the 


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1 Internal Revenue Code of 1986 is amended to read 

2 as follows: 

3 ‘‘(1) the applicable credit amount in effect 

4 under section 2010(c) for such calendar year (deter5 mined as if the basic exclusion amount in section 

6 2010(c)(2)(A) were $1,000,000), reduced by’’. 

7 (c) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to estates of decedents dying, and 

9 generation-skipping transfers and gifts made, after De10 cember 31, 2021. 

11 SEC. 3. MODIFICATION OF RULES FOR VALUE OF CERTAIN 

12 FARM, ETC., REAL PROPERTY. 

13 (a) IN GENERAL.—Paragraph (2) of section 

14 2032A(a) of the Internal Revenue Code of 1986 is amend15 ed by striking ‘‘$750,000’’ and inserting ‘‘$3,000,000’’. 

16 (b) INFLATION ADJUSTMENT.—Paragraph (3) of sec17 tion 2032A(a) of such Code is amended— 

18 (1) by striking ‘‘1998’’ and inserting ‘‘2022’’, 

19 (2) by striking ‘‘$750,000’’ each place it ap20 pears and inserting ‘‘$3,000,000’’, and 

21 (3) by striking ‘‘calendar year 1997’’ and in22 serting ‘‘calendar year 2021’’ in subparagraph (B). 

23 (c) EFFECTIVE DATE.—The amendments made by 

24 this section shall apply to estates of decedents dying, and 

25 gifts made, after December 31, 2021. 


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1 SEC. 4. MODIFICATION OF ESTATE TAX RULES WITH RE2 SPECT TO LAND SUBJECT TO CONSERVATION 

3 EASEMENTS. 

4 (a) MODIFICATION OF EXCLUSION LIMITATION.— 

5 Subparagraph (B) of section 2031(c)(1) of the Internal 

6 Revenue Code of 1986 is amended by striking ‘‘$500,000’’ 

7 and inserting ‘‘$2,000,000’’. 

8 (b) MODIFICATION OF APPLICABLE PERCENTAGE.— 

9 Paragraph (2) of section 2031(c) of the Internal Revenue 

10 Code of 1986 is amended by striking ‘‘40 percent’’ and 

11 inserting ‘‘60 percent’’. 

12 (c) EFFECTIVE DATE.—The amendments made by 

13 this section shall apply to estates of decedents dying, and 

14 gifts made, after December 31, 2021. 

15 SEC. 5. DISALLOWANCE OF STEP-UP IN BASIS FOR PROP16 ERTY HELD IN CERTAIN GRANTOR TRUSTS. 

17 (a) IN GENERAL.—Section 1014 of the Internal Rev18 enue Code of 1986 is amended— 

19 (1) by redesignating subsection (f) as sub20 section (g), and 

21 (2) by inserting after subsection (e) the fol22 lowing: 

23 ‘‘(f) PROPERTY HELD IN CERTAIN GRANTOR

24 TRUSTS.—This section shall not apply to property— 


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1 ‘‘(1) held in a trust of which the transferor is 

2 considered the owner under subpart E of part I of 

3 subchapter J, and 

4 ‘‘(2) if, after the transfer of such property to 

5 the trust, such property is not includible in the gross 

6 estate of the transferor for purposes of chapter 11.’’. 

7 (b) CONFORMING AMENDMENT.—Section 6662(k) of 

8 the Internal Revenue Code of 1986 is amended by striking 

9 ‘‘1014(f)’’ and inserting ‘‘1014(g)’’. 

10 (c) EFFECTIVE DATE.—The amendments made by 

11 this section shall apply to transfers after the date of the 

12 enactment of this Act. 

13 SEC. 6. VALUATION RULES FOR CERTAIN TRANSFERS OF 

14 NONBUSINESS ASSETS; LIMITATION ON MI15 NORITY DISCOUNTS. 

16 (a) IN GENERAL.—Section 2031 of the Internal Rev17 enue Code of 1986 is amended by redesignating subsection 

18 (d) as subsection (f) and by inserting after subsection (c) 

19 the following new subsections: 

20 ‘‘(d) VALUATION RULES FOR CERTAIN TRANSFERS

21 OF NONBUSINESS ASSETS.—For purposes of this chapter 

22 and chapter 12— 

23 ‘‘(1) IN GENERAL.—In the case of the transfer 

24 of any interest in an entity other than an interest 


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1 which is actively traded (within the meaning of sec2 tion 1092)— 

3 ‘‘(A) the value of any nonbusiness assets 

4 held by the entity with respect to such interest 

5 shall be determined as if the transferor had 

6 transferred such assets directly to the trans7 feree (and no valuation discount shall be al8 lowed with respect to such nonbusiness assets), 

9 and 

10 ‘‘(B) such nonbusiness assets shall not be 

11 taken into account in determining the value of 

12 the interest in the entity. 

13 ‘‘(2) NONBUSINESS ASSETS.—For purposes of 

14 this subsection— 

15 ‘‘(A) IN GENERAL.—The term ‘nonbusi16 ness asset’ means any asset which is not used 

17 in the active conduct of 1 or more trades or 

18 businesses. 

19 ‘‘(B) EXCEPTION FOR CERTAIN PASSIVE

20 ASSETS.—Except as provided in subparagraph 

21 (C), a passive asset shall not be treated for pur22 poses of subparagraph (A) as used in the active 

23 conduct of a trade or business unless— 

24 ‘‘(i) the asset is property described in 

25 paragraph (1) or (4) of section 1221(a) or 


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1 is a hedge with respect to such property, 

2 or 

3 ‘‘(ii) the asset is real property used in 

4 the active conduct of 1 or more real prop5 erty trades or businesses (within the mean6 ing of section 469(c)(7)(C)) in which the 

7 transferor materially participates and with 

8 respect to which the transferor meets the 

9 requirements of section 469(c)(7)(B)(ii). 

10 For purposes of clause (ii), material participa11 tion shall be determined under the rules of sec12 tion 469(h), except that section 469(h)(3) shall 

13 be applied without regard to the limitation to 

14 farming activity. 

15 ‘‘(C) EXCEPTION FOR WORKING CAP16 ITAL.—Any asset (including a passive asset) 

17 which is held as a part of the reasonably re18 quired working capital needs of a trade or busi19 ness shall be treated as used in the active con20 duct of a trade or business. 

21 ‘‘(3) PASSIVE ASSET.—For purposes of this 

22 subsection, the term ‘passive asset’ means any— 

23 ‘‘(A) cash or cash equivalents, 


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1 ‘‘(B) except to the extent provided by the 

2 Secretary, stock in a corporation or any other 

3 equity, profits, or capital interest in any entity, 

4 ‘‘(C) evidence of indebtedness, option, for5 ward or futures contract, notional principal con6 tract, or derivative, 

7 ‘‘(D) asset described in clause (iii), (iv), or 

8 (v) of section 351(e)(1)(B), 

9 ‘‘(E) annuity, 

10 ‘‘(F) real property used in 1 or more real 

11 property trades or businesses (as defined in sec12 tion 469(c)(7)(C)), 

13 ‘‘(G) asset (other than a patent, trade14 mark, or copyright) which produces royalty in15 come, 

16 ‘‘(H) commodity, 

17 ‘‘(I) collectible (within the meaning of sec18 tion 408(m)), or 

19 ‘‘(J) any other asset specified in regula20 tions prescribed by the Secretary. 

21 ‘‘(4) LOOK-THRU RULES.— 

22 ‘‘(A) IN GENERAL.—If a nonbusiness asset 

23 of an entity consists of a 10-percent interest in 

24 any other entity, this subsection shall be ap25 plied by disregarding the 10-percent interest 


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1 and by treating the entity as holding directly its 

2 ratable share of the assets of the other entity. 

3 This subparagraph shall be applied successively 

4 to any 10-percent interest of such other entity 

5 in any other entity. 

6 ‘‘(B) 10-PERCENT INTEREST.—The term 

7 ‘10-percent interest’ means— 

8 ‘‘(i) in the case of an interest in a cor9 poration, ownership of at least 10 percent 

10 (by vote or value) of the stock in such cor11 poration, 

12 ‘‘(ii) in the case of an interest in a 

13 partnership, ownership of at least 10 per14 cent of the capital or profits interest in the 

15 partnership, and 

16 ‘‘(iii) in any other case, ownership of 

17 at least 10 percent of the beneficial inter18 ests in the entity. 

19 ‘‘(5) COORDINATION WITH SUBSECTION (b).— 

20 Subsection (b) shall apply after the application of 

21 this subsection. 

22 ‘‘(e) LIMITATION ON MINORITY DISCOUNTS.—For 

23 purposes of this chapter and chapter 12, in the case of 

24 the transfer of any interest in an entity other than an in25 terest which is actively traded (within the meaning of secVerDate Sep 11 2014 03:42 Jun 02, 2021 Jkt 019200 PO 00000 Frm 00009 Fmt 6652 Sfmt 6201 E:\BILLS\H2576.IH H2576

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1 tion 1092), no discount shall be allowed by reason of the 

2 fact that the transferee does not have control of such enti3 ty, or by reason of the lack of marketability of the interest, 

4 if the transferor, the transferee, and members of the fam5 ily (as defined in section 2032A(e)(2)) of the transferor 

6 and transferee— 

7 ‘‘(1) have control of such entity, or 

8 ‘‘(2) own the majority of the ownership inter9 ests (by value) in such entity.’’. 

10 (b) EFFECTIVE DATE.—The amendments made by 

11 this section shall apply to transfers after the date of the 

12 enactment of this Act. 

13 SEC. 7. REQUIRED MINIMUM 10-YEAR TERM, ETC., FOR 

14 GRANTOR RETAINED ANNUITY TRUSTS. 

15 (a) IN GENERAL.—Subsection (b) of section 2702 of 

16 the Internal Revenue Code of 1986 is amended— 

17 (1) by redesignating paragraphs (1), (2), and 

18 (3) as subparagraphs (A), (B), and (C), respectively, 

19 and by moving such subparagraphs (as so redesig20 nated) 2 ems to the right; 

21 (2) by striking ‘‘For purposes of’’ and inserting 

22 the following: 

23 ‘‘(1) IN GENERAL.—For purposes of’’; 


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1 (3) by striking ‘‘paragraph (1) or (2)’’ in para2 graph (1)(C) (as so redesignated) and inserting 

3 ‘‘subparagraph (A) or (B)’’; and 

4 (4) by adding at the end the following new 

5 paragraph: 

6 ‘‘(2) ADDITIONAL REQUIREMENTS WITH RE7 SPECT TO GRANTOR RETAINED ANNUITIES.—For 

8 purposes of subsection (a), in the case of an interest 

9 described in paragraph (1)(A) (determined without 

10 regard to this paragraph) which is retained by the 

11 transferor, such interest shall be treated as de12 scribed in such paragraph only if— 

13 ‘‘(A) the right to receive the fixed amounts 

14 referred to in such paragraph is for a term of 

15 not less than 10 years and not more than the 

16 life expectancy of the annuitant plus 10 years, 

17 ‘‘(B) such fixed amounts, when determined 

18 on an annual basis, do not decrease during the 

19 term described in subparagraph (A), and 

20 ‘‘(C) the remainder interest has a value, as 

21 determined as of the time of the transfer, which 

22 is— 

23 ‘‘(i) not less than an amount equal to 

24 the greater of— 


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1 ‘‘(I) 25 percent of the fair mar2 ket value of the property in the trust, 

3 or 

4 ‘‘(II) $500,000, and 

5 ‘‘(ii) not greater than the fair market 

6 value of the property in the trust.’’. 

7 (b) EFFECTIVE DATE.—The amendments made by 

8 this section shall apply to transfers made after the date 

9 of the enactment of this Act. 

10 SEC. 8. CERTAIN TRANSFER TAX RULES APPLICABLE TO 

11 GRANTOR TRUSTS. 

12 (a) IN GENERAL.—Subtitle B of the Internal Rev13 enue Code of 1986 is amended by adding at the end the 

14 following new chapter: 

15 ‘‘CHAPTER 16—SPECIAL RULES FOR 

16 GRANTOR TRUSTS 

‘‘Sec. 2901. Application of transfer taxes. 

17 ‘‘SEC. 2901. APPLICATION OF TRANSFER TAXES. 

18 ‘‘(a) IN GENERAL.—In the case of any portion of a 

19 trust to which this section applies— 

20 ‘‘(1) the value of the gross estate of the de21 ceased deemed owner of such portion shall include 

22 all assets attributable to that portion at the time of 

23 the death of such owner, 


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1 ‘‘(2) any distribution from such portion to one 

2 or more beneficiaries during the life of the deemed 

3 owner of such portion shall be treated as a transfer 

4 by gift for purposes of chapter 12, and 

5 ‘‘(3) if at any time during the life of the 

6 deemed owner of such portion, such owner ceases to 

7 be treated as the owner of such portion under sub8 part E of part 1 of subchapter J of chapter 1, all 

9 assets attributable to such portion at such time shall 

10 be treated for purposes of chapter 12 as a transfer 

11 by gift made by the deemed owner. 

12 ‘‘(b) PORTION OF TRUST TO WHICH SECTION AP13 PLIES.—This section shall apply to— 

14 ‘‘(1) the portion of a trust with respect to 

15 which the grantor is the deemed owner, and 

16 ‘‘(2) the portion of the trust to which a person 

17 who is not the grantor is a deemed owner by reason 

18 of the rules of subpart E of part 1 of subchapter J 

19 of chapter 1, and such deemed owner engages in a 

20 sale, exchange, or comparable transaction with the 

21 trust that is disregarded for purposes of subtitle A. 

22 For purposes of paragraph (2), the portion of the trust 

23 described with respect to a transaction is the portion of 

24 the trust attributable to the property received by the trust 

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1 from, appreciation thereon, and reinvestments thereof, net 

2 of the amount of consideration received by the deemed 

3 owner in such transaction. 

4 ‘‘(c) EXCEPTIONS.—This section shall not apply to 

5 any trust that is includible in the gross estate of the 

6 deemed owner (without regard to subsection (a)(1)). 

7 ‘‘(d) DEEMED OWNER DEFINED.—For purposes of 

8 this section, the term ‘deemed owner’ means any person 

9 who is treated as the owner of a portion of a trust under 

10 subpart E of part 1 of subchapter J of chapter 1. 

11 ‘‘(e) REDUCTION FOR TAXABLE GIFTS TO TRUST

12 MADE BY OWNER.—The amount to which subsection (a) 

13 applies shall be reduced by the value of any transfer by 

14 gift by the deemed owner to the trust previously taken 

15 into account by the deemed owner under chapter 12. 

16 ‘‘(f) LIABILITY FOR PAYMENT OF TAX.—Any tax im17 posed pursuant to subsection (a) shall be a liability of the 

18 trust.’’. 

19 (b) CLERICAL AMENDMENT.—The table of chapters 

20 for subtitle B of such Code is amended by adding at the 

21 end the following new item: 

‘‘CHAPTER 16. SPECIAL RULES FOR GRANTOR TRUSTS’’. 

22 (c) EFFECTIVE DATE.—The amendments made by 

23 this section shall apply— 

24 (1) to trusts created on or after the date of the 

25 enactment of this Act, 


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1 (2) to any portion of a trust established before 

2 the date of the enactment of this Act which is attrib3 utable to a contribution made on or after such date, 

4 and 

5 (3) to any portion of a trust established before 

6 the date of the enactment of this Act to which sec7 tion 2901(a) of the Internal Revenue Code of 1986 

8 (as added by subsection (a)) applies by reason of a 

9 transaction described in section 2901(b)(2) of such 

10 Code on or after such date. 

11 SEC. 9. ELIMINATION OF GENERATION-SKIPPING TRANS12 FER TAX EXEMPTION FOR CERTAIN TRUSTS. 

13 (a) IN GENERAL.—Section 2642 of the Internal Rev14 enue Code of 1986 is amended by adding at the end the 

15 following new subsection: 

16 ‘‘(h) ELIMINATION OF GST EXEMPTION FOR CER17 TAIN TRUSTS.— 

18 ‘‘(1) IN GENERAL.— 

19 ‘‘(A) TRANSFERS FROM NON-QUALIFYING

20 TRUSTS.—In the case of any generation-skip21 ping transfer made from a trust that is not a 

22 qualifying trust, the inclusion ratio with respect 

23 to any property transferred in such transfer 

24 shall be 1. 


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1 ‘‘(B) QUALIFYING TRUST.—For purposes 

2 of this subsection, the term ‘qualifying trust’ 

3 means a trust for which the date of termination 

4 of such trust is not greater than 50 years after 

5 the date on which such trust is created. 

6 ‘‘(2) TRUSTS CREATED BEFORE DATE OF EN7 ACTMENT.—In the case of any trust created before 

8 the date of the enactment of this subsection, such 

9 trust shall be deemed to be a qualifying trust for a 

10 period of 50 years after the date of the enactment 

11 of this subsection. 

12 ‘‘(3) DATE OF CREATION OF CERTAIN DEEMED

13 SEPARATE TRUSTS.—In the case of any portion of a 

14 trust which is treated as a separate trust under sec15 tion 2654(b)(1), such separate trust shall be treated 

16 as created on the date of the first transfer described 

17 in such section with respect to such separate trust. 

18 ‘‘(4) DATE OF CREATION OF POUR-OVER

19 TRUSTS.—In the case of any generation-skipping 

20 transfer of property which involves the transfer of 

21 property from 1 trust to another trust, the date of 

22 the creation of the transferee trust shall be treated 

23 as being the earlier of— 

24 ‘‘(A) the date of the creation of such trans25 feree trust, or 


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1 ‘‘(B) the date of the creation of the trans2 feror trust. 

3 In the case of multiple transfers to which the pre4 ceding sentence applies, the date of the creation of 

5 the transferor trust shall be determined under the 

6 preceding sentence before the application of the pre7 ceding sentence to determine the date of the creation 

8 of the transferee trust. 

9 ‘‘(5) REGULATIONS.—The Secretary may pre10 scribe such regulations or other guidance as may be 

11 necessary or appropriate to carry out this sub12 section.’’. 

13 (b) EFFECTIVE DATE.—The amendments made by 

14 this section shall take effect on the date of the enactment 

15 of this Act. 

16 SEC. 10. SIMPLIFYING GIFT TAX EXCLUSION FOR ANNUAL 

17 GIFTS. 

18 (a) IN GENERAL.—Paragraph (1) of section 2503(b) 

19 of the Internal Revenue Code of 1986 is amended to read 

20 as follows: 

21 ‘‘(1) IN GENERAL.— 

22 ‘‘(A) LIMIT PER DONEE.—In the case of 

23 gifts made to any person by the donor during 

24 the calendar year, the first $10,000 of such 

25 gifts to such person shall not, for purposes of 


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1 subsection (a), be included in the total amount 

2 of gifts made during such year. 

3 ‘‘(B) CUMULATIVE LIMIT PER DONOR.— 

4 ‘‘(i) IN GENERAL.—The aggregate 

5 amount excluded under subparagraph (A) 

6 with respect to all transfers described in 

7 clause (ii) made by the donor during the 

8 calendar year shall not exceed twice the 

9 dollar amount in effect under such sub10 paragraph for such calendar year. 

11 ‘‘(ii) TRANSFERS SUBJECT TO LIMITA12 TION.—The transfers described in this 

13 clause are— 

14 ‘‘(I) a transfer in trust, 

15 ‘‘(II) a transfer of an interest in 

16 a passthrough entity, 

17 ‘‘(III) a transfer of an interest 

18 subject to a prohibition on sale, and 

19 ‘‘(IV) any other transfer of prop20 erty that, without regard to with21 drawal, put, or other such rights in 

22 the donee, cannot immediately be liq23 uidated by the donee.’’. 


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1 (b) CONFORMING AMENDMENT.—Section 2503 of the 

2 Internal Revenue Code of 1986 is amended by striking 

3 subsection (c). 

4 (c) REGULATIONS.—The Secretary of the Treasury, 

5 or the Secretary of the Treasury’s delegate, may prescribe 

6 such regulations or other guidance as may be necessary 

7 or appropriate to carry out the amendments made by this 

8 section. 

9 (d) EFFECTIVE DATE.—The amendments made by 

10 this section shall apply to any calendar year beginning 

11 after the date of the enactment of this Act. 

Æ 


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