respect to any taxpayer for any taxable year, the excess (if any), determined as of the close of such taxable year, of— (A) the estimated value of all assets of the taxpayer and all trust attributed assets of the taxpayer, as determined under regulations provided by the Secretary, over (B) all debts (and such other liabilities as the Secretary may provide) of the taxpayer and all trust attributed debts of the taxpayer. (3) Trust attributed assets The term trust attributed assets means, with respect to any taxpayer— (A) any asset of a trust which such taxpayer is treated as owning under subpart E of part I of subchapter J of chapter 1, and (B) any asset of a trust (other than a trust which a person other than the taxpayer is treated as owning under such subpart) that is distributable to the taxpayer or from which income is distributable to the taxpayer in whole or in part, whether or not the taxpayer’s distribution rights are subject to a contingency, unless that contingency is the death of another trust beneficiary. (4) Trust attributed debts The term trust attributed debts means, with respect to any taxpayer— (A) any debt (and such other liabilities as the Secretary may provide) of a trust described in paragraph (3)(A), and (B) any debt (and such other liabilities as the Secretary may provide) with respect to an asset described in paragraph (3)(B) if the holders of such debt have a right to repayment which is senior to the distribution rights of the taxpayer. (5) Gratuitous transfers (A) In general In the case of any asset which was transferred by the taxpayer during the 5-year period ending with the close of the taxable year for which the taxpayer’s net worth is determined (and which is not otherwise taken into account in determining such net worth), such taxpayer’s net worth (as determined for purposes of this section) shall be— (i) increased by the value of such transferred asset at the time of transfer, (ii) decreased (but not in excess of the amount of the increase under clause (i)) by the amount paid in