Subsection (a) shall not apply to a transfer to a trust by a United States person to the extent that any United States person is treated as the owner of such trust under section
671.
Subsection (a) shall not apply to a lifetime transfer to a nonresident alien.
Another section 1131(b) of
Pub. L. 105–34 amended sections
367,
721, and
1035 of this title.
Amendment by
Pub. L. 107–16 applicable to transfers after Dec. 31, 2009, see section 542(f)(2) of
Pub. L. 107–16, set out as a note under section
121 of this title.
Amendment by
Pub. L. 107–16 inapplicable to estates of decedents dying, gifts made, or generation skipping transfers, after Dec. 31, 2010, and the Internal Revenue Code of 1986 to be applied and administered to such estates, gifts, and transfers as if such amendment had never been enacted, see section 901 of
Pub. L. 107–16, set out as a note under section
1 of this title.