§2641 — Applicable rate
4 citing cases
Statute Text — 26 U.S.C. §2641
For purposes of this chapter, the term “applicable rate” means, with respect to any generation-skipping transfer, the product of—
the maximum Federal estate tax rate, and
the inclusion ratio with respect to the transfer.
For purposes of subsection (a), the term “maximum Federal estate tax rate” means the maximum rate imposed by section 2001 on the estates of decedents dying at the time of the taxable distribution, taxable termination, or direct skip, as the case may be.
Treasury Regulations
-
Treas. Reg. §26.2641-1Applicable rate of tax
The rate of tax applicable to any GST (applicable rate) is determined by multiplying the maximum Federal estate tax rate in effect at the time of the GST by the inclusion ratio (as defined in § 26.2642-1). For this purpose, the maximum Federal estate tax rate is the maximum rate set forth under section 2001(c) (without regard to section 2001(c)(2)).