Sec. 11061. Increase in estate and gift tax exemption
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Section 2010(c)(3) is amended by adding at the end the following new subparagraph: In the case of estates of decedents dying or gifts made after December 31, 2017, and before January 1, 2026, subparagraph
(A)shall be applied by substituting $10,000,000 for $5,000,000 . . Subsection
(g)of section 2001 is amended to read as follows: For purposes of applying subsection (b)(2) with respect to 1 or more gifts, the rates of tax under subsection
(c)in effect at the decedent's death shall, in lieu of the rates of tax in effect at the time of such gifts, be used both to compute— the tax imposed by chapter 12 with respect to such gifts, and the credit allowed against such tax under section 2505, including in computing— the applicable credit amount under section 2505(a)(1), and the sum of the amounts allowed as a credit for all preceding periods under section 2505(a)(2). The Secretary shall prescribe such regulations as may be necessary or appropriate to carry out this section with respect to any difference between— the basic exclusion amount under section 2010(c)(3) applicable at the time of the decedent's death, and the basic exclusion amount under such section applicable with respect to any gifts made by the decedent. . The amendments made by this section shall apply to estates of decedents dying and gifts made after December 31, 2017.