; table of contents. TITLE I—American opportunity accounts Sec. 101. Definitions. Sec. 102. American Opportunity Fund. Sec. 103. AO accounts. Sec. 104. Assignment, alienation, and treatment of deceased individuals. Sec. 105. Rules governing AO accounts relating to investment, accounting, and reporting. Sec. 106. American Opportunity Fund Board. Sec. 107. Fiduciary responsibilities. Sec. 108. Accounts disregarded in determining eligibility for Federal benefits. Sec. 109. Reports. Sec. 110. Programs for promoting financial capability. Sec. 111. Tax treatment. TITLE II—Revenue provisions Subtitle A—Estate and gift tax provisions Sec. 201. Modification of estate tax rate and basic exclusion amount. Sec. 202. Required minimum 10-year term, etc., for grantor retained annuity trusts. Sec. 203. Certain transfer tax rules applicable to grantor trusts. Sec. 204. Simplifying gift tax exclusion for annual gifts. Sec. 205. Modification of rules for value of certain farm real property. Subtitle B—Reform of taxation of capital income Sec. 211. Increase in capital gains rate. Sec. 212. Deemed realization of capital gains at time of gift or death. Sec. 213. Exclusion of certain amounts of realized capital gain. Sec. 214. Extension of time for payment of tax. Sec. 215. Waiver of penalty for underpayment of estimated tax. Sec. 216. Effective date. I American opportunity accounts 101. Definitions For purposes of this title— (1) American Opportunity Fund The term American Opportunity Fund means the fund established under section 102. (2) AO account The term AO account means an American opportunity account established under section 103. (3) Secretary The term Secretary means the Secretary of the Treasury or the Secretary’s delegate. (4) American Opportunity Fund Board The term American Opportunity Fund Board means the board established pursuant to section 106. (5) Executive Director The term Executive Director means the executive director appointed pursuant to section 106. 102. American Opportunity Fund (a) Establishment There is