as the owner of such trust (or a portion thereof) under subpart E of part 1 of subchapter J. (d) Rule of construction For purposes of subsection (a), a transfer of property for consideration shall include— (1) any satisfaction of an annuity, or (2) any discharge of debt, by the trust in kind. . (b) Related taxpayers Section 267(b) of the Internal Revenue Code of 1986 is amended— (1) by striking or at the end of paragraph (12), (2) by striking the period at the end of paragraph (13) and inserting