same beneficiaries shall be treated as a single appli-
cable taxpayer for purposes of this section. 
‘‘(4) DEFINITIONS.—For purposes of this sec-
tion: 
‘‘(A) GRANTOR TRUST.—The term ‘grantor 
trust’ means a trust in which a taxpayer is 
treated as owning an asset of the trust under 
subpart E of part I of subchapter J of chapter 
1. 
‘‘(B) BENEFICIARY
TRUST.—The term 
‘beneficiary trust’ means any trust that is not 
a grantor trust. 
‘‘(g) REGULATIONS.—The Secretary shall issue such 
regulations or other guidance as may be necessary or ap-
propriate to carry out the purposes of this section, includ-
ing— 
‘‘(1) regulations establishing a process by which 
a beneficiary may demonstrate the portion of such 
beneficiary’s interest in a trust, and 
‘‘(2) regulations for determining the appro-
priate attribution of assets in a trust for purposes 
of subsection (e)(1) in the case of a trust with mul-
tiple grantors. 
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‘‘SEC. 2902. NET VALUE OF TAXABLE ASSETS. 
‘‘(a) IN GENERAL.—For purposes of this subtitle, the 
term ‘net value of all taxable assets’ means, as of any date, 
the excess of— 
‘‘(1) the value of all property of the taxpayer 
(other than property excluded under subsection (b)), 
real or personal, tangible or intangible, wherever sit-
uated, over 
‘‘(2) any debts (including any debts secured by 
property excluded under subsection (b)) owed by the 
taxpayer. 
‘‘(b) EXCLUSION
FOR CERTAIN ASSETS UNDER 
$50,000.—Property of the taxpayer shall not be taken 
into account under subsection (a) if such property— 
‘‘(1) has a value of $50,000 or less (determined 
without regard to any debt owed by the taxpayer 
with respect to such property), 
‘‘(2) is tangible personal property, and 
‘‘(3) is not property— 
‘‘(A) which is used in a trade or business 
of the taxpayer, 
‘‘(B) in connection with which a deduction 
is allowable under section 212, or 
‘‘(C) which is a collectible as defined in 
section 408(m), a boat, an aircraft, a mobile 
home, a trailer, a vehicle, or an antique or other 
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asset that maintains or increases its value over 
time (within the meaning of section 5.02(2) of 
Revenue Procedure 2018–08). 
‘‘(c) RULES FOR DETERMINING PROPERTY OF THE 
TAXPAYER.—For purposes of this subtitle: 
‘‘(1) PROPERTY
INCLUDED
IN
ESTATE.—Any 
property that would be included in the estate of the 
taxpayer if the taxpayer died shall be treated as 
property of the taxpayer. 
‘‘(2) INCLUSION
OF
CERTAIN
GIFTS.—Any 
property transferred by the taxpayer after the date 
of the enactment of this chapter, to an individual 
who is a member of the family of the taxpayer (as 
determined under section 267(c)(4)) and has not at-
tained the age of 18 shall be treated as property of 
the taxpayer for any calendar year before the year 
in which such individual attains the age of 18. 
‘‘(d) ESTABLISHMENT OF VALUATION RULES.—Not 
later than 12 months after the date of the enactment of 
this section, the Secretary shall establish rules and meth-
ods for determining the value of any asset for purposes 
of this subtitle, including rules for the valuation of assets 
that are not publicly traded or that do not have a readily 
ascertainable value. Such rules and methods— 
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‘‘(1) may utilize retrospective and prospective 
formulaic valuation methods not currently in use by 
the Secretary, 
‘‘(2) may require the use of formulaic valuation 
approaches 
for 
designated 
assets, 
including 
formulaic approaches based on proxies for deter-
mining presumptive valuations, formulaic approaches 
based on prospective adjustments from purchase 
prices or other prior events, or formulaic approaches 
based on retrospectively adding deferral charges 
based on eventual sale prices or other specified later 
events indicative of valuation, and 
‘‘(3) may address the use of valuation dis-
counts. 
‘‘SEC. 2903. SPECIAL RULES. 
‘‘(a) DECEASED INDIVIDUALS.— 
‘‘(1) IN GENERAL.—In the case of any indi-
vidual who dies during a calendar year and who is 
not married on the date of such individual’s death— 
‘‘(A) section 2901 shall be applied by sub-
stituting ‘the date of the applicable taxpayer’s 
death’ for ‘the last day of any calendar year’, 
and 
‘‘(B) the amount of the tax imposed under 
such section shall be reduced by an amount 
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which bears the same ratio to such amount (de-
termined without regard to this subsection) 
as— 
‘‘(i) the number of days in the cal-
endar year after the date of the individ-
ual’s death, bears to 
‘‘(ii) 365. 
‘‘(2) COORDINATION WITH ESTATE TAX.—For 
purposes of section 2053, the tax imposed by this 
section for the year of the decedent’s death shall be 
considered to have been imposed before such death. 
‘‘(b) APPLICATION TO NON-RESIDENTS.—In the case 
of any nonresident alien individual, this subtitle shall 
apply only to the property of such individual which is situ-
ated in the United States (determined under rules similar 
to the rules under subchapter B of chapter 11). 
‘‘(c) APPLICATION TO COVERED EXPATRIATES.—In 
the case of an individual who is a covered expatriate (as 
defined in section 877A), section 2901(a) shall be applied 
as if the calendar year ended on the day before the expa-
triation. 
‘‘SEC. 2904. INFORMATION REPORTING. 
‘‘(a) IN GENERAL.—Not later than 12 months after 
the date of the enactment of this section, the Secretary 
shall by regulation require the reporting of any informa-
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