; or , and (3) by adding at the end the following new paragraph: (14) A grantor trust and the person treated as the owner of the trust (or portion thereof) under subpart E of part 1 of subchapter J of this chapter. . (c) Clerical amendments The table of sections for part IV of subchapter O of chapter 1 of the Internal Revenue Code of 1986 is amended by striking the item relating to section 1062 and inserting the following new items: Sec. 1062. Certain sales to grantor trusts. Sec. 1063. Cross references. . (d) Effective dates The amendments made by this section shall apply to transfers made after the date of the enactment of this Act. 4. Payment of tax on income of grantor trust (a) In general Section 2503 of the Internal Revenue Code of 1986 is amended— (1) in subsection (a), by striking The term and inserting Subject to subsection (d), the term and (2) by inserting after subsection (c) the following: (d) Payment of tax on income of grantor trust (1) In general Notwithstanding subsections (b) and (e), an amount equal to the taxes paid on the income of an applicable grantor trust for any calendar year by a person who is the deemed owner of such trust (or portion thereof) shall be treated for purposes of this subtitle as a taxable gift made during such calendar year. (2) Applicable grantor trust For purposes of this subsection, the term applicable grantor trust means any trust— (A) with respect to which the taxpayer is considered an owner under subpart E of part I of subchapter J of chapter 1, and (B) which is not fully revocable by the taxpayer. (3) Reimbursement by trust Paragraph (1) shall not apply with respect to any amount paid by the deemed owner for any calendar year which is reimbursed by the applicable grantor trust during such calendar year. (4) Date of gift In the case of any amount treated for purposes of this subtitle as a taxable gift pursuant to paragraph (1), such gift shall be deemed to have occurred on the earlier of— (A) December 31 of the calendar year for which the tax is paid by the person