Section 2653. Taxation of multiple skips (a) General rule

-For purposes of this chapter, if-    (1) there is a generation-skipping transfer of any property, and
    (2) immediately after such transfer such property is held in trust,
    for  purposes  of  applying  this chapter (other than section 2651) to
  subsequent transfers from the portion of such trust attributable to such
  property, the trust will  be  treated  as  if  the  transferor  of  such
  property  were  assigned  to  the  first  generation  above  the highest
  generation of any person who has an interest in such  trust  immediately
  after the transfer.
    (b) Trust retains inclusion ratio.-
    (1) In general.-Except as provided in paragraph (2), the provisions of
  subsection  (a)  shall  not  affect  the inclusion ratio determined with
  respect to any trust. Under regulations  prescribed  by  the  Secretary,
  notwithstanding  the preceding sentence, proper adjustment shall be made
  to the inclusion ratio with respect to such trust to take  into  account

  any  tax under this chapter borne by such trust which is imposed by this
  chapter on the transfer described in subsection (a).
    (2) Special rule for pour-over trust.-
    (A)  In  general.-If  the  generation-skipping transfer referred to in
  subsection (a) involves the transfer  of  property  from  one  trust  to
  another  trust  (hereinafter  in  this  paragraph  referred  to  as  the
  "pour-over trust"), the inclusion ratio for the pour-over trust 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.
    (B)  Nontax  portion.-For  purposes  of  subparagraph  (A), the nontax
  portion  of  any  distribution  is  the  amount  of  such   distribution
  multiplied   by   the   applicable   fraction   which  applies  to  such
  distribution.