Section 1022. Imposition of tax

A  tax  is  hereby  imposed upon every
  generation-skipping transfer which includes  New  York  property  in  an
  amount  computed by multiplying the maximum amount allowable as a credit
  for state generation-skipping transfer taxes under section two  thousand
  six  hundred  four  of  the  internal  revenue  code  by a fraction, the
  numerator of which is the value of the New York property included in the
  generation-skipping transfer and the denominator of which is  the  value
  of  all  the  property included in the generation-skipping transfer. The
  person liable for payment of the  federal  generation-skipping  transfer
  tax shall be liable for the tax imposed by this section.