; 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. . 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)