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Replaces subsection (a) to change how the tentative tax is computed — the tentative tax is to be computed under a rate schedule set forth in a new paragraph (2) (i.e., under 2502(a)(2)) rather than by reference to section 2001(c). Adds an internal rate schedule (paragraph (2)).
Amends paragraph (1) of section 2505(a) to define the applicable credit in terms of the tentative tax computed under the rate schedule in section 2502(a)(2) as if the amount were $10,000,000 (replacing the previous cross-reference to section 2010(c)). Also adds a new subsection (d) providing an inflation adjustment for the dollar amount in subsection (a)(1) for calendar years after 2011 and a rounding rule.
Strikes the existing cross-reference to 'section 2001(c) as in effect on the date of such receipt' and inserts a reference to 'section 2502(a)(2)'.
Adds a new section 2210 (titled 'Termination') to subchapter C of chapter 11 providing that the estate tax chapter shall not apply to estates of decedents dying on or after the date of enactment, with specific transitional rules for certain distributions from qualified domestic trusts under section 2056A for surviving spouses of decedents who died before enactment.
Adds a new section 2664 (titled 'Termination') to subchapter G of chapter 13 providing that the generation-skipping transfer tax chapter shall not apply to generation-skipping transfers on or after the date of enactment.
Repeals the federal estate tax and the generation‑skipping transfer (GST) tax for transfers occurring on or after the date of enactment, and replaces prior lifetime gift rules with a new $10,000,000 lifetime gift exemption indexed for inflation (with specified rounding). The changes also update related table/heading language and include transition rules that govern transfers occurring in the calendar year of enactment.
The changes apply to estates, generation‑skipping transfers, and gifts on or after enactment, and will substantially alter estate and gift tax liabilities, estate‑planning behavior, and federal revenue from wealth‑transfer taxation.
Referred to the House Committee on Ways and Means.
Introduced February 13, 2025 by Randy Feenstra · Last progress February 13, 2025