of— (A) the date of the creation of such transferee trust, or (B) the date of the creation of the transferor trust. In the case of multiple transfers to which the preceding sentence applies, the date of the creation of the transferor trust shall be determined under the preceding sentence before the application of the preceding sentence to determine the date of the creation of the transferee trust. (5) Regulations The Secretary may prescribe such regulations or other guidance as may be necessary or appropriate to carry out this subsection. . (b) Effective date The amendments made by this section shall take effect on the date of the enactment of this Act. 406. Simplifying gift tax exclusion for annual gifts (a) In general Paragraph (1) of section 2503(b) is amended to read as follows: (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 twice the dollar amount in effect under such subparagraph for such calendar year. (ii) Transfers subject to limitation The transfers described in this clause are— (I) a transfer in trust, (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. . (b) Conforming amendment Section 2503 is amended by striking subsection (c). (c) Regulations The Secretary of the Treasury, or the Secretary of the Treasury's delegate, may prescribe such regulations or other guidance as may be necessary or appropriate to carry out the amendments made by this