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Generation-skipping transfer tax
The U.S. generation-skipping transfer tax imposes a tax on both outright gifts and transfers in trust to or for the benefit of unrelated persons who are more than 37.5 years younger than the donor or to related persons more than one generation younger than the donor, such as grandchildren.〔See IRS Form 709 Instructions〕 The generation-skipping tax will be imposed only if the transfer avoids incurring a gift or estate tax at each generation level.
For example, property is placed in a trust for the donor's child and grandchildren. The income may be distributed among the child and grandchildren in accordance with their needs and the principal of the trust will be distributed outright to the grandchildren following the child's death. If the trust property is not subject to estate tax at the child's death, a generation-skipping tax will be imposed when the child dies.
== The first version of the tax (1976) ==
The first version of the generation-skipping tax was introduced in 1976.〔The Tax Reform Act of 1976, Pub. L. No. 94-455, § 2006, 90 Stat. 1520, 1879−90.〕 That version attempted to impose a generation-skipping tax exactly equal to the estate or gift tax that was avoided. In the above example, the Executor of the child's Will would have had to determine the estate tax, if any, the child's estate owed without regard to the existence of the trust. Then the Trustee of trust would have to use the child's Federal Estate Tax Return as the basis for recomputing the child's estate tax liability as if the trust property had been part of the child's estate.
抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』
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