26 U.S.C. § 2641

1. (a)For purposes of this chapter, the term “applicable rate” means, with respect to any generation-skipping transfer, the product of—
   1. (1)the maximum Federal estate tax rate, and
   2. (2)the inclusion ratio with respect to the transfer.
2. (b)For purposes of subsection (a), the term “maximum Federal estate tax rate” means the maximum rate imposed by section 2001 on the estates of decedents dying at the time of the taxable distribution, taxable termination, or direct skip, as the case may be.