; and (3) to any portion of a trust established before the date of the enactment of this Act to which section 2901(a) of the Internal Revenue Code of 1986 (as added by subsection (a)) applies by reason of a transaction described in section 2901(b)(2) of such Code on or after such date. 204. Simplifying gift tax exclusion for annual gifts (a) In general Section 2503 of the Internal Revenue Code of 1986 is amended— (1) by striking paragraph (1) of subsection (b) and inserting the following: (1) In general (A) Limit per donee In the case of gifts made to any person by the donor during the calendar year, the first $10,000 of such gifts to such person shall not, for purposes of subsection (a), be included in the total amount of gifts made during such year. (B) Cumulative limit per donor (i) In general The aggregate amount excluded under subparagraph (A) with respect to all transfers described in clause (ii) made by the donor during the calendar year shall not exceed $50,000. (ii) Transfers subject to limitation The transfers described in this clause are— (I) a transfer in trust (with the exception of any transfer to a trust described in section 2642(c)(2)), (II) a transfer of an interest in a passthrough entity, (III) a transfer of an interest subject to a prohibition on sale, and (IV) any other transfer of property that, without regard to withdrawal, put, or other such rights in the donee, cannot immediately be liquidated by the donee. , and (2) by striking subsection (c). (b) Conforming amendments (1) Subparagraph (B) of section 529(c)(2) of the Internal Revenue Code of 1986 is amended by striking section 2503(b) and inserting “section 2503(b)(1)(A). (2) Clause (i) of section 529A(b)(2)(B) of such Code is amended by striking section 2503(b) and inserting section 2503(b)(1)(A) . (3) Paragraph (2) of section 2523(i) of such Code is amended by striking section 2503(b) and inserting section 2503(b)(1)(A) . (4) Subsection (c) of such Code of section 2801 is amended by striking 2503(b) and inserting 2503(b)(1)(A) . (c)