date on which such trust is created. (2) Trusts created before date of enactment In the case of any trust created before the date of the enactment of this subsection, such trust shall be deemed to be a qualifying trust for a period of 50 years after the date of the enactment of this subsection. (3) Date of creation of certain deemed separate trusts In the case of any portion of a trust which is treated as a separate trust under section 2654(b)(1), such separate trust shall be treated as created on the date of the first transfer described in such section with respect to such separate trust. (4) Date of creation of pour-over trusts In the case of any generation-skipping transfer of property which involves the transfer of property from 1 trust to another trust, the date of the creation of the transferee trust shall be treated as being the earlier 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. 10. Simplifying gift tax exclusion for annual gifts (a) In general Paragraph (1) of section 2503(b) of the Internal Revenue Code of 1986 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