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 transfers to certain persons (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 transfers to certain persons (1) In general (A) Transfer to non-exempt person In the case of any direct skip or taxable distribution made to any person who is not an exempt person, the inclusion ratio shall be 1. (B) Taxable termination In the case of any taxable termination which occurs at any time immediately after no exempt person is a beneficiary of the trust, the inclusion ratio shall be 1. (C) Exempt person (i) In general For purposes of this subsection, the term exempt person means— (I) a natural person— (aa) who is assigned to a generation which is 2 or fewer generations below the generation assignment of the transferor, or (bb) whose date of birth precedes the date on which the trust was created, or (II) a trust in which all interests are held by persons described in subclause (I). (ii) Exception For purposes of clause (i)(II), any interest