Increases the unified estate and gift tax credit to $1.3 million.
Repeals the estate and gift tax provisions applicable to family-owned businesses.
Amends provisions concerning the special rules for allocation of the generation-skipping tax (GST) exemption to provide, as a general rule, that: (1) if any individual makes an indirect skip during such individual's lifetime, any unused portion of such individual's GST exemption shall be allocated to the property transferred to the extent necessary to make the inclusion ratio for such property zero; and (2) if the amount of the indirect skip exceeds such unused portion, the entire unused portion shall be allocated to the property transferred.
Declares that, if a trust is severed in a qualified severance, the trusts resulting from such severance shall be treated as separate trusts thereafter.
Revises valuation rules for gifts for which a gift tax return was filed or deemed allocation made. Provides that, if an allocation of the GST exemption to any transfers of property is deemed to have been made at the close of an estate tax inclusion period, the value of the property shall be its value at such time.
Directs the Secretary of the Treasury to prescribe circumstances and procedures under which extensions of time will be granted to make an allocation of GST exemption or an election not to apply specified allocation requirements to certain lifetime direct skips, indirect skips, or transfers to a particular trust.
Increases the permissible number of partners or shareholders in a closely held business for purposes of eligibility for an extension of estate tax payments.