applicable taxpayer means any individual or any trust (other than a trust described in section 401(a) and exempt from tax under section 501(a)). (2) Treatment of married individuals For purposes of this section, individuals who are married (as defined in section 7703) shall be treated as one applicable taxpayer. (d) Threshold amount For purposes of this section, the term threshold amount means the amount that is the product of 1,000 multiplied by the greater of— (1) $50,000, or (2) the applicable median house hold wealth. (e) Applicable median household wealth The Secretary shall annually determine the median household wealth with respect to the United States for purposes of this section. (f) Application to trusts (1) Attribution of assets in trust In determining the assets of a taxpayer for purposes of subsection (a): (A) Grantor trust In the case of a grantor trust, the grantor shall be treated as holding all the assets of the trust. (B) Beneficiary trust In the case of a beneficiary trust, each beneficiary of the trust shall be treated as holding a fraction of the assets of the trust in proportion to such beneficiary’s interest in such trust. (2) Property of trusts Any asset treated as held by a grantor or beneficiary under paragraph (1) shall not be treated as held by the trust for purposes of this section. (3) Trusts relating to common beneficiaries Trusts benefitting substantially the same beneficiaries shall be treated as a single applicable taxpayer for purposes of this section. (4) Definitions For purposes of this section: (A) Grantor trust The term grantor trust means a trust in which a taxpayer is treated as owning an asset of the trust under subpart E of part I of subchapter J of chapter 1. (B) Beneficiary trust The term beneficiary trust means any trust that is not a grantor trust. (g) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this section, including— (1) regulations establishing a process by which a