for taxable gifts to trust made by owner The amount to which subsection (a) applies shall be reduced by the value of any transfer by gift by the deemed owner to the trust previously taken into account by the deemed owner under chapter 12. (f) Liability for payment of tax Any tax imposed pursuant to subsection (a) shall be a liability of the trust. . (b) Clerical amendment The table of chapters for subtitle B of such Code is amended by adding at the end the following new item: Chapter 16. special rules for grantor trusts . (c) Effective date The amendments made by this section shall apply— (1) to trusts created on or after the date of the enactment of this Act, (2) to any portion of a trust established before the date of the enactment of this Act which is attributable to a contribution made on or after such date, 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. 9. Elimination of generation-skipping transfer tax exemption for certain trusts (a) In general Section 2642 of the Internal Revenue Code of 1986 is amended by adding at the end the following new subsection: (h) Elimination of GST exemption for certain trusts (1) In general (A) Transfers from non-qualifying trusts In the case of any generation-skipping transfer made from a trust that is not a qualifying trust, the inclusion ratio with respect to any property transferred in such transfer shall be 1. (B) Qualifying trust For purposes of this subsection, the term qualifying trust means a trust for which the date of termination of such trust is not greater than 50 years after the 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