Taxation of Estates and Gifts

Skip Person

A skip person is an individual two or more generations below the the transferor. 26 U.S.C. § 2613(a)(1).

A trust also counts as a skip person if all interests are held by skip people. 26 U.S.C. § 2613(a)(2).

Entities are treated as being owned by the individuals owning them. 26 U.S.C. § 2651(f)(2).


A skip person has an interest in a trust if he can receive current distributions of income or principal. 26 U.S.C. § 2552(c).

This is different that what is a "present interest" for annual exclusion purposes.