Title 26, Internal Revenue CodeRelease 119-110
§2621 Taxable Amount in Case of Taxable Distribution
Title 26 › Subtitle B — Estate and Gift Taxes › CHAPTER 13 — TAX ON GENERATION-SKIPPING TRANSFERS › Subchapter C — Taxable Amount › § 2621
Summary
To figure the taxable part of a taxable distribution, use the value of the property the recipient gets and subtract any costs the recipient paid to figure out, pay, or get a refund of the tax on that distribution. If the trust pays any of that tax, the amount it pays counts as a taxable distribution to the recipient.
Full Legal Text
Title 26, §2621
Internal Revenue Code, Source: USLM XML via OLRC
(a)In general
For purposes of this chapter, the taxable amount in the case of any taxable distribution shall be—
(1)the value of the property received by the transferee, reduced by
(2)any expense incurred by the transferee in connection with the determination, collection, or refund of the tax imposed by this chapter with respect to such distribution.
(b)Payment of GST tax treated as taxable distribution
For purposes of this chapter, if any of the tax imposed by this chapter with respect to any taxable distribution is paid out of the trust, an amount equal to the portion so paid shall be treated as a taxable distribution.
Legislative History
Notes & Related Subsidiaries
Editorial Notes
Amendments
1986—Pub. L. 99–514 amended section generally, substituting provisions relating to taxable amount in case of a taxable distribution for former provisions which related generally to administration of this chapter. See section 2661 of this title. 1981—Subsec. (b). Pub. L. 97–34 substituted “section 6166” for “section 6166 and 6166A” in heading and “section 6166 (relating to extension of time” for “section 6166 and 6166A (relating to extensions of time” in text.
Statutory Notes and Related Subsidiaries
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.
Effective Date
of 1981 AmendmentAmendment by Pub. L. 97–34 applicable to estates of decedents dying after Dec. 31, 1981, see section 422(f)(1) of Pub. L. 97–34, set out as a note under section 6166 of this title.
Reference
Citations & Metadata
Citation
26 U.S.C. § 2621
Title 26, Internal Revenue Code
Last Updated
Sep 22, 2026
Release point: 119-110