§1431

Neumann v. Commissioner, 106 T.C. 216 (1996), we addressed the application of the generation-skipping transfer (GST) tax to "direct skip" transfers by non- resident aliens. Section 2663(2), enacted in the Tax Reform Act of 1986, Pub. L. No. 99-514, sec. 1431(a), 100 Stat. at 2729, provided: "The Secretary shall pre- 4Subsequent cases finding to be self-executing Code sections providing that the Secretary "shall prescribe regulations" have stressed the provisions' taxpayer- friendly character. In

Children who regularly reside outside the United States may qualify for naturalization under 8 U.S.C. sec. 1433 (2012).7 In pertinent part, 8 U.S.C. sec. 1433 provides: SEC. 1433. CHILDREN BORN AND RESIDING OUTSIDE THE UNITED STATES; CONDITIONS FOR ACQUIRING CERTIFICATE OF CITIZENSHIP. (a) Application by citizen parents; requireme

1431 (2006)(relating to children born outside ofthe United States and residing permanently in the United States)). Petitioners have another child, their tenth, who was born in November 2008 and became a U.S. citizen in October 2009. 3 See generally sec. 6013 (permittingjoint returns by husband and wife). See sec. 6013(g) (permitting an electio

Children who regularly reside outside the United States may qualify for naturalization under 8 U.S.C. sec. 1433 (2012). In pertinent part, 8 U.S.C. sec. 1433 provides: SEC. 1433. CHILDREN BORN AND RESIDING OUTSIDE THE UNITED STATES; CONDITIONS FOR ACQUIRING CERTIFICATE OF CITIZENSHIP. (a) Application by citizen parents; requiremen

ointment means “a power which is exercisable in favor of the decedent, his estate, his creditors, or the creditors of his estate”. Sec. 2041(b)(1).3 GST tax generally applies to any generation-skipping transfer made after October 22, 1986. TRA 1986 sec. 1431(a). However, TRA 1986 section 1433(b)(2)(A) provides special transitional rules or “grandfather” provisions excepting certain transfers from the reach of the GST tax. TRA 1986 section 1433(b)(2)(A) provides: 3 It follows that a decedent who

ppointment means “a power which is exercisable in favor of the decedent, his estate, his creditors, or the creditors of his estate”. Sec. 2041(b)(1). GST tax generally applies to any generation-skipping transfer made after October 22, 1986. TRA 1986 sec. 1431(a). However, TRA 1986 section 1433(b)(2)(A) provides special transitional rules or “grandfather” provisions excepting certain transfers from the reach of the GST tax. TRA 1986 section 1433(b)(2)(A) provides: (b) Special Rules.— # % ‡ ‡ ‡ Hí

t 592. In 1986, dissatisfied with the GST tax, Congress retroactively repealed the 1976 provisions and enacted new provisions extending the GST tax to "direct skip" transfers such as are involved herein. See Tax Reform Act of 1986, Pub. L. 99- 514, sec. 1431, 100 Stat. 2085, 2717.2 Section 2663, enacted in 1986, provided: The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out the purposes of this chapter, including-- * * * * * * * (2) regulations (consiste

Although section 2663, which was added by TRA 1986 section 1431(a), 100 Stat.