26 U.S.C. § 2611

Generation-skipping transfer defined

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(a) In generalFor purposes of this chapter, the term “generation-skipping transfer” means—(1) a taxable distribution,(2) a taxable termination, and(3) a direct skip.(b) Certain transfers excludedThe term “generation-skipping transfer” does not include—(1) any transfer which, if made inter vivos by an individual, would not be treated as a taxable gift by reason of section 2503(e) (relating to exclusion of certain transfers for educational or medical expenses), and(2) any transfer to the extent—(A) the property transferred was subject to a prior tax imposed under this chapter,(B) the transferee in the prior transfer was assigned to the same generation as (or a lower generation than) the generation assignment of the transferee in this transfer, and(C) such transfers do not have the effect of avoiding tax under this chapter with respect to any transfer.(Added Pub. L. 94–455, title XX, § 2006(a), Oct. 4, 1976, 90 Stat. 1882; amended Pub. L. 99–514, title XIV, § 1431(a), Oct. 22, 1986, 100 Stat. 2718; Pub. L. 100–647, title I, §§ 1014(g)(1), (2), 1018(u)(43), Nov. 10, 1988, 102 Stat. 3562, 3592.)Editorial NotesAmendments

1988—Subsec. (a). Pub. L. 100–647, §§ 1014(g)(1), 1018(u)(43), substituted “generation-skipping transfer” for “generation-skipping transfers” and “means” for “mean”.

Subsec. (b). Pub. L. 100–647, § 1014(g)(2), redesignated pars. (2) and (3) as (1) and (2), respectively, and struck out former par. (1) which read as follows: “any transfer (other than a direct skip) from a trust, to the extent such transfer is subject to a tax imposed by chapter 11 or 12 with respect to a person in the 1st generation below that of the grantor, and”.

1986—Pub. L. 99–514 amended section generally, substituting provisions defining “generation-skipping transfers” and what that term does not include, for former provisions which defined “generation-skipping transfer”, “transfer”, and “generation-skipping trust”, contained provisions to be used in determining the ascertainment of generation, and provided for a generation-skipping trust equivalent.

Statutory Notes and Related SubsidiariesEffective Date of 1988 Amendment

Amendment by Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.

Effective Date of 1986 Amendment

Section applicable to generation-skipping transfers (within the meaning of section 2611 of this title) made after Oct. 22, 1986, except as otherwise provided, see section 1433 of Pub. L. 99–514, set out as a note under section 2601 of this title.

Notes of Decisions
Cited in 68 cases (1 in the last 5 years), 1928–2021 · leading case: Oak Worsted Mills v. United States, 36 F.2d 529 (Ct. Cl. 1929).
Oak Worsted Mills v. United States, 36 F.2d 529 (Ct. Cl. 1929). · cites it 5× “) Section 611 (26 USCA § 2611) provides: “If any internal-revenue tax (or any interest, penalty, additional amount, or addition to such tax) was, within the period of limitation properly applicable thereto, assessed prior to June 2,1924, and if a claim in abatement was filed,…”
Goodcell v. Graham, 35 F.2d 586 (9th Cir. 1929). · cites it 6× “875 , 26 USCA § 2611). The appellees brought an action to recover $9,039.”
BankBoston v. Marlow, 428 Mass. 283 (Mass. 1998). “26 U.S.C.A. §§ 2611 , 2612 (West 1989 & Supp.”
Naumkeag Steam Cotton Co. v. United States, 2 F. Supp. 126 (Ct. Cl. 1933). · cites it 2× “152, an opinion made and published by the general counsel of the Bureau of Internal Revenue, it was held that section 611 of the Revenue Act of 1928 (26 USCA § 2611), was not applicable to the case where a claim for credit of an overpayment had operated to stay the collection of…”
Regla Coal Co. v. Bowers, 37 F.2d 373 (S.D.N.Y. 1929). · cites it 9× “Case the court decided that “stayed,” in a legal sense, is not interchangeable with “delayed,” and necessarily connotes “some act on the part of the taxpayer whieh would morally or legally tie the hands of the Commissioner and prevent collection of the tax”; and since article…”
Rockland & Rockport Lime Corp. v. Ham, 38 F.2d 239 (D. Me. 1930). · cites it 3× “The defendant contends that, as to the excess profits taxes involved, they were not paid after the limitation period had expired, and as to the income taxes involved, while conceding that the five-year limitation period had expired before their payment, relies upon section 611…”
Simmons Mfg. Co. v. Routzahn, 62 F.2d 947 (6th Cir. 1933). · cites it 2× “Section 607 thereof (26 USCA § 2607) classified as overpayments taxes assessed or paid after the expiration of the period of limitation properly applicable, while section 611 (26 USCA § 2611) made an important exception there *948 to.”
Hartwell Mills v. Rose, 61 F.2d 441 (5th Cir. 1932). “…[607], relating to payments made after the expiration of the period of limitation on assessment and collection.” (26 USCA § 2611.)”
Wright & Taylor, Inc. v. Lucas, 45 F.2d 75 (6th Cir. 1930). · cites it 3× “Section 607 (26 USCA § 2607), in harmony with the Bowers Case, provided that any tax paid after the expiration of the applicable limitation period shall be considered an overpayment and refundable if properly claimed, but section 611 (26 USCA § 2611) made an important exception.”
Imhoff-Berg Silk Dyeing Co. v. United States, 43 F.2d 836 (D.N.J. 1930). · cites it 10× “It is admitted that plaintiff’s suit is timely and properly brought, and that, were it not for the provisions of section 611 of the Revenue Act of 1928 (26 USCA § 2611), the plaintiff’s right to a return of its money would be clear under the terms of section 607 (26 USCA § 2607).”
Parks & Woolson MacH. Co. v. United States, 58 F.2d 868 (Ct. Cl. 1932). “In that ease recovery was denied under the provisions of section 611 of the 1928 Act (26 USCA § 2611). The credit involved in that ease was not void.”
Savannah Bank & Trust Co. v. United States, 58 F.2d 1068 (Ct. Cl. 1932). “The record in this case shows that the official schedule rejecting plaintiffs’ elaim for refund was signed and approved by the commissioner on August 9, 1929. This suit was therefore timely instituted.”
— 26 U.S.C. § 2611(2)(D) — 1 case
Woldeselassie v. Am. Eagle Airlines, Inc., 647 F. App'x 21 (2d Cir. 2016).
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