tion 2901(a) of the Internal Revenue Code of 1986 
(as added by subsection (a)) applies by reason of a 
transaction described in section 2901(b)(2) of such 
Code on or after such date. 
SEC. 9. ELIMINATION OF GENERATION-SKIPPING TRANS-
FER TAX EXEMPTION FOR CERTAIN TRUSTS. 
(a) IN GENERAL.—Section 2642 of the Internal Rev-
enue Code of 1986 is amended by adding at the end the 
following new subsection: 
‘‘(h) ELIMINATION OF GST EXEMPTION FOR CER-
TAIN TRUSTS.— 
‘‘(1) IN GENERAL.— 
‘‘(A) TRANSFERS FROM NON-QUALIFYING 
TRUSTS.—In the case of any generation-skip-
ping transfer made from a trust that is not a 
qualifying trust, the inclusion ratio with respect 
to any property transferred in such transfer 
shall be 1. 
‘‘(B) QUALIFYING TRUST.—For purposes 
of this subsection, the term ‘qualifying trust’ 
means a trust for which the date of termination 
of such trust is not greater than 50 years after 
the date on which such trust is created. 
‘‘(2) TRUSTS CREATED BEFORE DATE OF EN-
ACTMENT.—In the case of any trust created before 
VerDate Sep 11 2014 
02:01 Jul 01, 2015
Jkt 049200
PO 00000
Frm 00025
Fmt 6652
Sfmt 6201
E:\BILLS\H2907.IH
H2907
SSpencer on DSK4SPTVN1PROD with BILLS
the date of the enactment of this subsection, such 
trust shall be deemed to be a qualifying trust for a 
period of 50 years after the date of the enactment 
of this subsection. 
‘‘(3) DATE OF CREATION OF CERTAIN DEEMED 
SEPARATE TRUSTS.—In the case of any portion of a 
trust which is treated as a separate trust under sec-
tion 2654(b)(1), such separate trust shall be treated 
as created on the date of the first transfer described 
in such section with respect to such separate trust. 
‘‘(4) DATE
OF
CREATION
OF
POUR-OVER 
TRUSTS.—In the case of any generation-skipping 
transfer of property which involves the transfer of 
property from 1 trust to another trust, the date of 
the creation of the transferee trust shall be treated 
as being the earlier of— 
‘‘(A) the date of the creation of such trans-
feree trust, or 
‘‘(B) the date of the creation of the trans-
feror trust. 
In the case of multiple transfers to which the 
preceding sentence applies, the date of the cre-
ation of the transferor trust shall be determined 
under the preceding sentence before the appli-
VerDate Sep 11 2014 
02:01 Jul 01, 2015
Jkt 049200
PO 00000
Frm 00026
Fmt 6652
Sfmt 6201
E:\BILLS\H2907.IH
H2907
SSpencer on DSK4SPTVN1PROD with BILLS
cation of the preceding sentence to determine 
the date of the creation of the transferee trust. 
‘‘(5) REGULATIONS.—The Secretary may pre-
scribe such regulations or other guidance as may be 
necessary or appropriate to carry out this sub-
section.’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act. 
SEC. 10. SIMPLIFYING GIFT TAX EXCLUSION FOR ANNUAL 
GIFTS. 
(a) IN GENERAL.—Section 2503(b)(1) of the Internal 
Revenue Code of 1986 is amended to read as follows: 
‘‘(1) IN GENERAL.— 
‘‘(A) LIMIT PER DONEE.—In the case of 
gifts made to any person by the donor during 
the calendar year, the first $10,000 of such 
gifts to such person shall not, for purposes of 
subsection (a), be included in the total amount 
of gifts made during such year. 
‘‘(B) CUMULATIVE LIMIT PER DONOR.— 
‘‘(i) IN
GENERAL.—The aggregate 
amount excluded under subparagraph (A) 
with respect to all transfers described in 
clause (ii) made by the donor during the 
VerDate Sep 11 2014 
02:01 Jul 01, 2015
Jkt 049200
PO 00000
Frm 00027
Fmt 6652
Sfmt 6201
E:\BILLS\H2907.IH
H2907
SSpencer on DSK4SPTVN1PROD with BILLS
calendar year shall not exceed twice the 
dollar amount in effect under such sub-
paragraph for such calendar year. 
‘‘(ii) TRANSFERS SUBJECT TO LIMITA-
TION.—The transfers described in this 
clause are— 
‘‘(I) a transfer in trust, 
‘‘(II) a transfer of an interest in 
a passthrough entity, 
‘‘(III) a transfer of an interest 
subject to a prohibition on sale, and 
‘‘(IV) any other transfer of prop-
erty that, without regard to with-
drawal, put, or other such rights in 
the donee, cannot immediately be liq-
uidated by the donee.’’. 
(b) CONFORMING AMENDMENT.—Section 2503 of the 
Internal Revenue Code of 1986 is amended by striking 
subsection (c). 
(c) REGULATIONS.—The Secretary of the Treasury, 
or the Secretary of the Treasury’s delegate, may prescribe 
such regulations or other guidance as may be necessary 
or appropriate to carry out the amendments made by this 
section. 
VerDate Sep 11 2014 
02:01 Jul 01, 2015
Jkt 049200
PO 00000
Frm 00028
Fmt 6652
Sfmt 6201
E:\BILLS\H2907.IH
H2907
SSpencer on DSK4SPTVN1PROD with BILLS
(d) EFFECTIVE DATE.—The amendments made by 
this section shall apply to any calendar year beginning 
after the date of the enactment of this Act. 
Æ 
VerDate Sep 11 2014 
02:01 Jul 01, 2015
Jkt 049200
PO 00000
Frm 00029
Fmt 6652
Sfmt 6301
E:\BILLS\H2907.IH
H2907
SSpencer on DSK4SPTVN1PROD with BILLS