I
106TH CONGRESS
1ST SESSION
H. R. 2760
To amend the Internal Revenue Code of 1986 to establish for certain employ-
ees of international organizations an estate tax credit equivalent to the
limited marital deduction.
IN THE HOUSE OF REPRESENTATIVES
AUGUST 5, 1999
Mr. HOUGHTON 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 establish
for certain employees of international organizations an
estate tax credit equivalent to the limited marital deduc-
tion.
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled,
SECTION 1. CREDIT EQUIVALENT TO LIMITED MARITAL DE-
DUCTION 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 DE-
DUCTION 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 sec-
tion 2001(b) or 2101(b) (whichever is applicable) shall be
reduced by the applicable marital transfer credit deter-
mined 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 resi-
dents of the United States, and
‘‘(B) either the decedent or the surviving
spouse of the decedent was a qualified inter-
national 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 ap-
plicable 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 the applicable exclu-
sion amount, over
‘‘(ii) a tentative tax computed under
section 2001(c) on the applicable exclusion
amount.
If the amount of the adjusted taxable gifts of
the decedent exceeds the applicable exclusion
amount, the amount of such gifts shall be sub-
stituted for the applicable exclusion amount 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) the applicable exclusion amount,
or
‘‘(ii) the excess of the sum referred to
in section 2001(b)(1) over the applicable
exclusion amount.
‘‘(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 para-
graph (1) with the following modifications—
‘‘(A) the amount set forth in subparagraph
(B)(i) shall be reduced by the deduction equiva-
lent of the section 2102 unified credit, and
‘‘(B) the deduction equivalent of the sec-
tion 2102 unified credit shall be substituted for
the applicable exclusion amount each place it
appears in paragraph (1) other than subpara-
graph (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
ORGANIZA-
TION 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