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Q: 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.
A:
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.