any calendar year beginning after the date of the enactment of this Act. 11. Gross up for taxable gifts (a) In general Section 2503 of the Internal Revenue Code of 1986, as amended by section 10, is amended— (1) in subsection (a), by striking The term and inserting Subject to subsection (c), the term , and (2) by inserting after subsection (b) the following: (c) Gross Up An amount equal to the taxes paid by an individual under section 2501 for any calendar year on the transfer of property by gift during such calendar year shall be treated for purposes of this subtitle as a taxable gift made during such calendar year. . (b) Effective date The amendments made by this section shall apply to calendar years beginning after the date of enactment of this Act. 12. Definition of executor (a) Establishment of general definition of executor for Internal Revenue Code of 1986 (1) Subchapter C of chapter 11 of subtitle B of the Internal Revenue Code of 1986 is amended by striking section 2203. (2) Section 7701(a) of such Code is amended by adding at the end the following: (51) Executor (A) In general The term executor means— (i) the executor or administrator of the decedent, or (ii) if there is no executor or administrator appointed, qualified, and acting within the United States, any person in actual or constructive possession of any property of the decedent. (B) Authority For purposes of this title, an executor shall be authorized to act on behalf of the decedent, including with respect to any liability or obligation incurred under this title which preceded the death of the decedent. (C) Regulations The Secretary shall issue such regulations or other guidance as may be necessary or appropriate to determine the executor of a decedent in the case where 2 or more persons satisfy the applicable requirements under subparagraph (A) with respect to the decedent. . (b) Conforming amendments (1) Section 2652 of the Internal Revenue Code of 1986 is amended by striking subsection (d). (2) Section 6036 of such Code is amended by