H.R. 9245 - American Housing and Economic Mobility Act of 2024

118TH CONGRESS
2D SESSION

H.R. 9245

To make housing more affordable, and for other purposes.

IN THE HOUSE OF REPRESENTATIVES

AUGUST 2, 2024

Mr. CLEAVER introduced the following bill; which was referred to the Committee on _____

A BILL

To make housing more affordable, and for other purposes.

Be it enacted by the Senate and House of Representatives of the United States of America in Congress assembled,

SECTION 1. SHORT TITLE; TABLE OF CONTENTS.

(a) SHORT TITLE. — This Act may be cited as the "American Housing and Economic Mobility Act of 2024".

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TITLE IV — ESTATE TAX REFORM

SEC. 401. AMENDMENT TO INTERNAL REVENUE CODE OF 1986.

Except as otherwise expressly provided, whenever in this title an amendment or repeal is expressed in terms of an amendment to, or repeal of, a section or other provision, the reference shall be considered to be made to a section or other provision of the Internal Revenue Code of 1986.

SEC. 402. RATE ADJUSTMENT.

(a) INCREASE IN ESTATE TAX RATES. — The table contained in section 2001(c) is amended to read as follows:

If the amount with respect to which the tentative tax to be computed is:	The tentative tax is:
Not over $13,000,000	55 percent of such amount.
Over $13,000,000 but not over $93,000,000.	$7,150,000, plus 60 percent of the excess of such amount over $13,000,000.
Over $93,000,000	$55,150,000, plus 65 percent of the excess of such amount over $93,000,000.

(b) REDUCTION OF BASIC EXCLUSION AMOUNT. — Paragraph (3) of section 2010(c) is amended to read as follows:

“(3) BASIC EXCLUSION AMOUNT. — For purposes of this subsection, the basic exclusion amount is $3,500,000.".

(c) SURTAX ON BILLION DOLLAR ESTATES. — Section 2001 is amended —

(1) in subsection (b), by striking "The tax" and inserting "Subject to subsection (h), the tax", and

(2) by adding at the end the following new subsection:

“(h) SURTAX ON BILLION DOLLAR ESTATES. —

“(1) IN GENERAL. — In the case of a taxable estate for which the applicable amount is in excess of $1,000,000,000, the tax determined under subsection (b) shall be increased by an amount equal to 10 percent of such applicable amount.

“(2) APPLICABLE AMOUNT. — For purposes of this subsection, the applicable amount shall be equal to the sum of the amounts under subparagraphs (A) and (B) of paragraph (1) of subsection (b) for the taxable estate.".

(d) EFFECTIVE DATE. — The amendments made by this section shall apply to estates of decedents dying, and generation-skipping transfers and gifts made, after the date of the enactment of this Act.

SEC. 403. REQUIRED MINIMUM 10-YEAR TERM, ETC., FOR GRANTOR RETAINED ANNUITY TRUSTS.

(a) IN GENERAL. — Subsection (b) of section 2702 is amended —

(1) by redesignating paragraphs (1), (2), and (3) as subparagraphs (A), (B), and (C), respectively, and by moving such subparagraphs (as so redesignated) 2 ems to the right;

(2) by striking "For purposes of" and inserting the following:

“(1) IN GENERAL. — For purposes of";

(3) by striking "paragraph (1) or (2)" in paragraph (1)(C) (as so redesignated) and inserting "subparagraph (A) or (B)"; and

(4) by adding at the end the following new paragraph:

“(2) ADDITIONAL REQUIREMENTS WITH RESPECT TO GRANTOR RETAINED ANNUITIES. — For purposes of subsection (a), in the case of an interest described in paragraph (1)(A) (determined without regard to this paragraph) which is retained by the transferor, such interest shall be treated as described in such paragraph only if —

“(A) the right to receive the fixed amounts referred to in such paragraph is for a term of not less than 10 years,

“(B) such fixed amounts, when determined on an annual basis, do not decrease relative to any prior year during the first 10 years of the term referred to in subparagraph (A), and

“(C) the remainder interest has a value equal to or greater than 10 percent of the value of the assets transferred to the trust, determined as of the time of the transfer.".

(b) EFFECTIVE DATE. — The amendments made by this section shall apply to transfers made after the date of the enactment of this Act.

SEC. 404. CERTAIN TRANSFER TAX RULES APPLICABLE TO GRANTOR TRUSTS.

(a) IN GENERAL. — Subtitle B is amended by adding at the end the following new chapter:

“CHAPTER 16 — SPECIAL RULES FOR GRANTOR TRUSTS

“Sec. 2901. Application of transfer taxes.

“SEC. 2901. APPLICATION OF TRANSFER TAXES.

“(a) IN GENERAL. — In the case of any portion of a trust to which this section applies —

“(1) the value of the gross estate of the deceased deemed owner of such portion shall include all assets attributable to that portion at the time of the death of such owner,

“(2) any distribution from such portion to one or more beneficiaries during the life of the deemed owner of such portion shall be treated as a transfer by gift for purposes of chapter 12, and

“(3) if at any time during the life of the deemed owner of such portion, such owner ceases to be treated as the owner of such portion under subpart E of part 1 of subchapter J of chapter 1, all assets attributable to such portion at such time shall be treated for purposes of chapter 12 as a transfer by gift made by the deemed owner.

“(b) PORTION OF TRUST TO WHICH SECTION APPLIES. — This section shall apply to —

“(1) the portion of a trust with respect to which the grantor is the deemed owner, and

“(2) the portion of the trust to which a person who is not the grantor is a deemed owner by reason of the rules of subpart E of part 1 of subchapter J of chapter 1, and such deemed owner engages in a sale, exchange, or comparable transaction with the trust that is disregarded for purposes of subtitle A.

For purposes of paragraph (2), the portion of the trust described with respect to a transaction is the portion of the trust attributable to the property received by the trust in such transaction, including all retained income therefrom, appreciation thereon, and reinvestments thereof, net of the amount of consideration received by the deemed owner in such transaction.

“(c) EXCEPTIONS. — This section shall not apply to —

“(1) any trust that is includible in the gross estate of the deemed owner (without regard to subsection (a)(1)), and

“(2) any other type of trust that the Secretary determines by regulations or other guidance does not have as a significant purpose the avoidance of transfer taxes.

“(d) DEEMED OWNER DEFINED. — For purposes of this section, the term 'deemed owner' means any person who is treated as the owner of a portion of a trust under subpart E of part 1 of subchapter J of chapter 1.

“(e) REDUCTION FOR TAXABLE GIFTS TO TRUST MADE BY OWNER. — The amount to which subsection (a) applies shall be reduced by the value of any transfer by gift by the deemed owner to the trust previously taken into account by the deemed owner under chapter 12.

“(f) LIABILITY FOR PAYMENT OF TAX. — Any tax imposed pursuant to subsection (a) shall be a liability of the trust.".

(b) CLERICAL AMENDMENT. — The table of chapters for subtitle B is amended by adding at the end the following new item:

“CHAPTER 16. SPECIAL RULES FOR GRANTOR TRUSTS".

(c) EFFECTIVE DATE. — The amendments made by this section shall apply —

(1) to trusts created on or after the date of the enactment of this Act;

(2) to any portion of a trust established before the date of the enactment of this Act which is attributable to a contribution made on or after such date; and

(3) to any portion of a trust established before the date of the enactment of this Act to which section 2901(a) of the Internal Revenue Code of 1986 (as added by subsection (a)) applies by reason of a transaction described in section 2901(b)(2) of such Code on or after such date.

SEC. 405. ELIMINATION OF GENERATION-SKIPPING TRANSFER TAX EXEMPTION FOR TRANSFERS TO CERTAIN PERSONS.

(a) IN GENERAL. — Section 2642 is amended by adding at the end the following new subsection:

“(h) ELIMINATION OF GST EXEMPTION FOR TRANSFERS TO CERTAIN PERSONS. —

“(1) IN GENERAL. —

“(A) TRANSFER TO NON-EXEMPT PERSON. — In the case of any direct skip or taxable distribution made to any person who is not an exempt person, the inclusion ratio shall be 1.

“(B) TAXABLE TERMINATION. — In the case of any taxable termination which occurs at any time immediately after no exempt person is a beneficiary of the trust, the inclusion ratio shall be 1.

“(C) EXEMPT PERSON. —

“(i) IN GENERAL. — For purposes of this subsection, the term 'exempt person' means —

“(I) a natural person —

“(aa) who is assigned to a generation which is 2 or fewer generations below the generation assignment of the transferor, or

“(bb) whose date of birth precedes the date on which the trust was created, or

“(II) a trust in which all interests are held by persons described in subclause (I).

“(ii) EXCEPTION. — For purposes of clause (i)(II), any interest which is used primarily to postpone or avoid the application of this subsection shall be disregarded.

“(2) DATE OF CREATION. —

“(A) IN GENERAL. — For purposes of determining the date on which a trust was created under paragraph (1)(C)(i)(I)(bb), if the trust was created before January 1, 2024, such trust shall be deemed to have been created on January 1, 2024.

“(B) DATE OF CREATION OF POUR-OVER TRUSTS. —

“(i) IN GENERAL. — In the case of any generation-skipping transfer of property which involves the transfer of property from one trust to another trust, the date of the creation of the transferee trust shall be treated as being the earlier of —

“(I) the date of the creation of such transferee trust, or

“(II) the date of the creation of the transferor trust.

“(ii) MULTIPLE TRANSFERS. — In the case of multiple transfers to which clause (i) applies —

“(I) the date of the creation of the transferor trust shall be determined under such clause, and

“(II) subsequent to the determination described in subclause (I), the date of the creation of the transferee trust shall be determined under such clause.

“(3) GENERATION ASSIGNMENT. — For purposes of this subsection, the provisions of section 2653(a) shall not apply.

“(4) REGULATIONS. — The Secretary may prescribe such regulations or other guidance as may be necessary or appropriate to carry out this subsection.".

(b) REPEAL. — Section 1433(b)(2) of the Tax Reform Act of 1986 (Public Law 99-514) is repealed.

(c) EFFECTIVE DATES. —

(1) IN GENERAL. — The amendment made by subsection (a) shall take effect on the date of the enactment of this Act.

(2) REPEAL. — The amendment made by subsection (b) shall apply to generation-skipping transfers (within the meaning of section 2611 of the Internal Revenue Code of 1986) made after the date of enactment of this Act.

SEC. 406. SIMPLIFYING GIFT TAX EXCLUSION FOR ANNUAL GIFTS.

(a) IN GENERAL. — Paragraph (1) of section 2503(b) is amended to read as follows:

“(1) IN GENERAL. —

“(A) LIMIT PER DONEE. — In the case of gifts made to any person by the donor during the calendar year, the first $10,000 of such gifts to such person shall not, for purposes of subsection (a), be included in the total amount of gifts made during such year.

“(B) CUMULATIVE LIMIT PER DONOR. —

“(i) IN GENERAL. — The aggregate amount excluded under subparagraph (A) with respect to all transfers described in clause (ii) made by the donor during the calendar year shall not exceed twice the dollar amount in effect under such subparagraph for such calendar year.

“(ii) TRANSFERS SUBJECT TO LIMITATION. — The transfers described in this clause are —

“(I) a transfer in trust,

“(II) a transfer of an interest in a passthrough entity,

“(III) a transfer of an interest subject to a prohibition on sale, and

“(IV) any other transfer of property that, without regard to withdrawal, put, or other such rights in the donee, cannot immediately be liquidated by the donee.".

(b) CONFORMING AMENDMENT. — Section 2503 is amended by striking subsection (c).

(c) REGULATIONS. — The Secretary of the Treasury, or the Secretary of the Treasury's delegate, may prescribe such regulations or other guidance as may be necessary or appropriate to carry out the amendments made by this section.

(d) EFFECTIVE DATE. — The amendments made by this section shall apply to any calendar year beginning after the date of the enactment of this Act.

SEC. 407. CLARIFICATION REGARDING DISALLOWANCE OF STEP-UP IN BASIS FOR PROPERTY HELD IN CERTAIN GRANTOR TRUSTS.

(a) IN GENERAL. — Section 1014 is amended —

(1) by redesignating subsection (f) as subsection (g), and

(2) by inserting after subsection (e) the following:

“(f) PROPERTY HELD IN CERTAIN GRANTOR TRUSTS. — This section shall not apply to property —

“(1) held in a trust of which the transferor is considered the owner under subpart E of part I of subchapter J, and

“(2) if, after the transfer of such property to the trust, such property is not includible in the gross estate of the transferor for purposes of chapter 11.".

(b) CONFORMING AMENDMENT. — Section 6662(k) is amended by striking "1014(f)" and inserting "1014(g)".

(c) EFFECTIVE DATE. — The amendments made by this section shall apply to transfers after the date of the enactment of this Act.

(d) NO INFERENCE. — No inference may be drawn from the amendments made by this section with respect to the application of section 1014 of the Internal Revenue Code of 1986 to property described in subsection (f) of such section (as added by subsection (a)) which was transferred on or before the date of enactment of this Act.

SEC. 408. LIMITATION ON DISCOUNTS; VALUATION RULES FOR CERTAIN TRANSFERS OF NONBUSINESS ASSETS.

(a) IN GENERAL. — Chapter 14 of subtitle B is amended by adding at the end the following new section:

“SEC. 2705. LIMITATION ON DISCOUNTS; VALUATION RULES FOR CERTAIN TRANSFERS OF NONBUSINESS ASSETS.

“(a) LIMITATION ON DISCOUNT BY REASON OF FAMILY CONTROL. —

“(1) IN GENERAL. — For purposes of this subtitle, in the case of the transfer of any interest in an entity other than an interest which is actively traded (within the meaning of section 1092), if the transferor, the transferee, and members of the family of the transferor and transferee have control of such entity immediately before such transfer, no discount shall be allowed —

“(A) by reason of the fact that the transferor or transferee does not have control of such entity,

“(B) by reason of the lack of marketability of the interest, or

“(C) for any other reason.

“(2) DEFINITIONS. — In this subsection, the terms 'control' and 'member of the family' have the same meanings given such terms in section 2704(c).

“(3) ATTRIBUTION. — For purposes of this section, the rule of section 2701(e)(3) shall apply for purposes of determining the interests held by any individual.

“(b) VALUATION RULES FOR CERTAIN TRANSFERS OF NONBUSINESS ASSETS. —

“(1) IN GENERAL. — For purposes of this subtitle, in the case of the transfer of any interest in an entity other than an interest which is actively traded (within the meaning of section 1092) —

“(A) the value of any nonbusiness assets held by the entity with respect to such interest shall be determined as if the transferor had transferred such assets directly to the transferee (and no valuation discount shall be allowed with respect to such nonbusiness assets), and

“(B) such nonbusiness assets shall not be taken into account in determining the value of the interest in the entity.

“(2) NONBUSINESS ASSETS. — For purposes of this subsection —

“(A) IN GENERAL. — The term 'nonbusiness asset' means any asset other than an asset which is used in the active conduct of a trade or business.

“(B) PASSIVE ASSETS TREATED AS NONBUSINESS ASSETS. —

“(i) IN GENERAL. — For purposes of subparagraph (A), a passive asset shall be treated as a nonbusiness asset unless —

“(I) the asset is property described in paragraph (1) or (4) of section 1221(a) or is a hedge with respect to such property, or

“(II) the asset is real property used in the active conduct of 1 or more real property trades or businesses (within the meaning of section 469(c)(7)(C)) in which the transferor materially participates and with respect to which the transferor meets the requirements of section 469(c)(7)(B)(ii).

“(ii) MATERIAL PARTICIPATION. — For purposes of clause (i)(II), material participation shall be determined under the rules of section 469(h), except that section 469(h)(3) shall be applied without regard to the limitation to farming activity.

“(C) WORKING CAPITAL TREATED AS USED IN TRADE OR BUSINESS. — Any asset (including a passive asset) which is held as a part of the reasonably required working capital needs of a trade or business shall be treated as used in the active conduct of a trade or business.

“(3) PASSIVE ASSET. — For purposes of this subsection, the term 'passive asset' means any —

“(A) cash or cash equivalents,

“(B) stock in a corporation or any other equity, profits, or capital interest in any entity,

“(C) evidence of indebtedness, option, forward or futures contract, notional principal contract, or derivative,

“(D) asset described in clause (iii), (iv), or (v) of section 351(e)(1)(B),

“(E) annuity,

“(F) real property used in 1 or more real property trades or businesses (as defined in section 469(c)(7)(C)),

“(G) asset (other than a patent, trademark, or copyright) which produces royalty income,

“(H) commodity,

“(I) collectible (within the meaning of section 408(m)), or

“(J) any other asset specified in regulations prescribed by the Secretary.

“(4) LOOK-THRU RULE. —

“(A) IN GENERAL. — If a nonbusiness asset of an entity described in paragraph (1) consists of a 10-percent interest in any other entity, this subsection shall be applied by disregarding the 10-percent interest and by treating the entity as holding directly its ratable share of the assets of the other entity.

“(B) 10-PERCENT INTEREST. — The term '10-percent interest' means —

“(i) in the case of an interest in a corporation, direct ownership of at least 10 percent (by vote or value) of the stock in such corporation,

“(ii) in the case of an interest in a partnership, direct ownership of at least 10 percent of the capital or profits interest in the partnership, and

“(iii) in any other case, direct ownership of at least 10 percent of the beneficial interests in the entity.".

(b) CONFORMING AMENDMENTS. —

(1) Section 2031(b) of the Internal Revenue Code of 1986 is amended by inserting "(after application of section 2705(b))" after "shall be determined".

(2) The table of sections of chapter 14 of subtitle B of such Code is amended by adding at the end the following:

“Sec. 2705. Limitation on discounts; valuation rules for certain transfers of nonbusiness assets.".

(c) EFFECTIVE DATE. — The amendments made by this section shall apply to transfers after the date of the enactment of this Act.

SEC. 409. SURCHARGE ON HIGH INCOME ESTATES AND TRUSTS.

(a) IN GENERAL. — Subchapter A of chapter 1 is amended by adding at the end the following new part:

“PART VIII — SURCHARGE ON HIGH INCOME ESTATES AND TRUSTS

“Sec. 59B. Surcharge on high income estates and trusts.

“SEC. 59B. SURCHARGE ON HIGH INCOME ESTATES AND TRUSTS.

“(a) GENERAL RULE. — In the case of an estate or trust, there is hereby imposed (in addition to any other tax imposed by this subtitle) a tax equal to the sum of —

“(1) 5 percent of so much of the modified adjusted gross income of the taxpayer as exceeds $200,000, plus

“(2) 3 percent of so much of the modified adjusted gross income of the taxpayer as exceeds $500,000.

“(b) MODIFIED ADJUSTED GROSS INCOME. — For purposes of this section —

“(1) IN GENERAL. — The term 'modified adjusted gross income' means adjusted gross income reduced by any deduction (not taken into account in determining adjusted gross income) allowed for investment interest (as defined in section 163(d)) or business interest (as defined in section 163(j)).

“(2) ADJUSTED GROSS INCOME. — Adjusted gross income shall be determined as provided in section 67(e) and reduced by the amount allowed as a deduction under section 642(c).

“(c) SPECIAL RULES. —

“(1) CHARITABLE TRUSTS. — Subsection (a) shall not apply to a trust all the unexpired interests in which are devoted to one or more of the purposes described in section 170(c)(2)(B).

“(2) NOT TREATED AS TAX IMPOSED BY THIS CHAPTER FOR CERTAIN PURPOSES. — The tax imposed under this section shall not be treated as tax imposed by this chapter for purposes of determining the amount of any credit under this chapter (other than sections 27 and 901) or for purposes of section 55.

“(3) ELECTING SMALL BUSINESS TRUSTS. — For purposes of the determination of adjusted gross income, section 641(c)(1)(A) shall not apply and all portions of any electing small business trust shall be treated as a single trust.

“(d) REGULATIONS. — The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including regulations or other guidance to prevent the avoidance of the purposes of this section.".

(b) COORDINATION WITH CERTAIN PROVISIONS. —

(1) INTEREST ON CERTAIN DEFERRED TAX LIABILITY. — Section 453A(c) is amended by redesignating paragraph (6) as paragraph (7) and by inserting after paragraph (5) the following new paragraph:

“(6) SURCHARGE ON HIGH INCOME ESTATES AND TRUSTS TAKEN INTO ACCOUNT IN DETERMINING MAXIMUM RATE OF TAX. — For purposes of paragraph (3)(B), in the case of an estate or trust, the maximum rate of tax in effect under section 1 shall be treated as being equal to the sum of such rate and the rates in effect under paragraphs (1) and (2) of section 59B(a).".

(2) LIMITATION ON FOREIGN TAX CREDIT. —

(A) Section 904(b)(3)(E)(i)(I) is amended by inserting "increased, in the case of an estate or trust, by the sum of the rates set forth in paragraphs (1) and (2) of section 1A(a)" after "(whichever applies)".

(B) Section 904(d)(2)(F) is amended by adding at the end the following: "For purposes of the first sentence of this subparagraph, in the case of an estate or trust, the highest rate of tax specified in section 1 shall be treated as being equal to the sum of such rate and the rates in effect under paragraphs (1) and (2) of section 59B(a).".

(3) ELECTION BY INDIVIDUALS TO BE SUBJECT TO TAX AT CORPORATE RATES. — Section 962(a)(1) is amended by striking "and 55" and inserting 55", and 59B".

(4) INTEREST ON CERTAIN TAX DEFERRAL. — Section 1291(c)(2) is amended by adding at the end the following: "For purposes of the preceding sentence, in the case of an estate or trust, the highest rate of tax in effect under section 1 shall be treated as being equal to the sum of such rate and the rates in effect under paragraphs (1) and (2) of section 59B(a).".

(5) WITHHOLDING OF TAX ON FOREIGN PARTNERS' SHARE OF EFFECTIVELY CONNECTED INCOME. — Section 1446(b)(2) is amended by adding at the end the following flush sentence:

“For purposes of subparagraph (A), in the case of a partner which is an estate or trust, the highest rate of tax in effect under section 1 shall be treated as being equal to the sum of such rate and the rates in effect under paragraphs (1) and (2) of section 59B(a).".

(6) PARTNERSHIP ADJUSTMENTS. —

(A) Section 6225(b)(1) is amended by adding at the end the following flush sentence:

“For purposes of subparagraph (B), in the case of an estate or trust, the highest rate of tax in effect under section 1 shall be treated as being equal to the sum of such rate and the rates in effect under paragraphs (1) and (2) of section 59B(a).".

(B) Section 6225(c)(4)(A) is amended —

(i) by striking "subsection (b)(1)(A)" and inserting "subsection (b)(1)(B)", and

(ii) by striking "or" at the end of clause (i), by adding "or" at the end of clause (ii), and by inserting after clause (ii) the following new clause:

“(iii) is not an estate or trust subject to one or both of the rates of tax in effect under paragraphs (1) and (2) of section 59B(a),".

(7) REQUIRED PAYMENTS FOR ENTITIES ELECTING NOT TO HAVE REQUIRED TAXABLE YEAR. — The second sentence of section 7519(b) is amended by inserting "and, in the case of an estate or trust, increased by the sum of the rates in effect under paragraphs (1) and (2) of section 59B(a)" before the period at the end.

(c) CLERICAL AMENDMENT. — The table of parts for subchapter A of chapter 1 is amended by adding at the end the following new item:

“PART VIII — SURCHARGE ON HIGH INCOME ESTATES AND TRUSTS".

(d) EFFECTIVE DATE. — The amendments made by this section shall apply to taxable years beginning after the date of the enactment of this Act.

SEC. 410. MODIFICATION OF RULES FOR VALUE OF CERTAIN FARM, ETC., REAL PROPERTY.

(a) IN GENERAL. — Paragraph (2) of section 2032A(a) of the Internal Revenue Code of 1986 is amended by striking "$750,000" and inserting "$3,000,000".

(b) INFLATION ADJUSTMENT. — Paragraph (3) of section 2032A(a) of such Code is amended —

(1) by striking "1998" and inserting "2025",

(2) by striking "$750,000" each place it appears and inserting "$3,000,000", and

(3) by striking "calendar year 1997" and inserting "calendar year 2024" in subparagraph (B).

(c) EFFECTIVE DATE. — The amendments made by this section shall apply to estates of decedents dying, and gifts made, after December 31, 2024.

SEC. 411. MODIFICATION OF ESTATE TAX RULES WITH RESPECT TO LAND SUBJECT TO CONSERVATION EASEMENTS.

(a) MODIFICATION OF EXCLUSION LIMITATION. — Subparagraph (B) of section 2031(c)(1) of the Internal Revenue Code of 1986 is amended by striking "$500,000" and inserting "$2,000,000".

(b) MODIFICATION OF APPLICABLE PERCENTAGE. — Paragraph (2) of section 2031(c) of the Internal Revenue Code of 1986 is amended by striking "40 percent" and inserting "60 percent".

(c) EFFECTIVE DATE. — The amendments made by this section shall apply to estates of decedents dying, and gifts made, after December 31, 2024.

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