---
kind: "section"
citation: "26 U.S.C. § 2653"
title: "26"
title_heading: "Internal Revenue Code"
number: "2653"
heading: "Taxation of multiple skips"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/2653"
units:
  - "Subtitle B — Estate and Gift Taxes"
  - "Chapter 13 — Tax on Generation-Skipping Transfers"
  - "Subchapter F — Other Definitions and Special Rules"
---

# §2653. Taxation of multiple skips

- (a) **General rule—** For purposes of this chapter, if—
  - (1) there is a [generation-skipping transfer](/usc/26/2611.md?p=a) of any property, and
  - (2) immediately after such transfer such property is held in [trust](/usc/26/2652.md?p=b-1),

  for purposes of applying this chapter (other than [section 2651](/usc/26/2651.md)) to subsequent transfers from the portion of such [trust](/usc/26/2652.md?p=b-1) attributable to such property, the [trust](/usc/26/2652.md?p=b-1) will be treated as if the [transferor](/usc/26/2652.md?p=a-1) of such property were assigned to the first generation above the highest generation of any person who has an interest in such [trust](/usc/26/2652.md?p=b-1) immediately after the transfer.

- (b) **Trust retains inclusion ratio—**
  - (1) **In general—** Except as provided in [paragraph (2)](#b-2), the provisions of [subsection (a)](#a) shall not affect the inclusion ratio determined with respect to any [trust](/usc/26/2652.md?p=b-1). Under regulations prescribed by the Secretary, notwithstanding the preceding sentence, proper adjustment shall be made to the inclusion ratio with respect to such [trust](/usc/26/2652.md?p=b-1) to take into account any tax under this chapter borne by such [trust](/usc/26/2652.md?p=b-1) which is imposed by this chapter on the transfer described in [subsection (a)](#a).
  - (2) **Special rule for pour-over trust—**
    - (A) **In general—** If the [generation-skipping transfer](/usc/26/2611.md?p=a) referred to in [subsection (a)](#a) involves the transfer of property from 1 [trust](/usc/26/2652.md?p=b-1) to another [trust](/usc/26/2652.md?p=b-1) (hereinafter in this paragraph referred to as the “pour-over [trust](/usc/26/2652.md?p=b-1)”), the inclusion ratio for the pour-over [trust](/usc/26/2652.md?p=b-1) shall be determined by treating the nontax portion of such distribution as if it were a part of a GST exemption allocated to such [trust](/usc/26/2652.md?p=b-1).
    - (B) **Nontax portion—** For purposes of [subparagraph (A)](#b-2-A), the nontax portion of any distribution is the amount of such distribution multiplied by the applicable fraction which applies to such distribution.

## Source credit

(Added Pub. L. 99–514, title XIV, § 1431(a), Oct. 22, 1986, 100 Stat. 2727.)

## Notes

### Statutory Notes and Related Subsidiaries

### Effective Date

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.