26 CFR § 26.2653-1 - Taxation of multiple skips.

---
identifier: "/us/cfr/t26/s26.2653-1"
source: "ecfr"
legal_status: "authoritative_unofficial"
title: "26 CFR § 26.2653-1 - Taxation of multiple skips."
title_number: 26
title_name: "Internal Revenue"
section_number: "26.2653-1"
section_name: "Taxation of multiple skips."
chapter_name: "INTERNAL REVENUE SERVICE, DEPARTMENT OF THE TREASURY"
subchapter_number: "B"
subchapter_name: "ESTATE AND GIFT TAXES"
part_number: "26"
part_name: "GENERATION-SKIPPING TRANSFER TAX REGULATIONS UNDER THE TAX REFORM ACT OF 1986"
positive_law: false
currency: "2026-03-24"
last_updated: "2026-03-24"
format_version: "1.1.0"
generator: "[email protected]"
authority: "26 U.S.C. 7805 and 26 U.S.C. 2663."
regulatory_source: "T.D. 8644, 60 FR 66903, Dec. 27, 1995, unless otherwise noted."
cfr_part: "26"
---


# 26.2653-1 Taxation of multiple skips.

(a) *General rule.* If property is held in trust immediately after a GST, solely for purposes of determining whether future events involve a skip person, the transferor is thereafter deemed to occupy the generation immediately above the highest generation of any person holding an interest in the trust immediately after the transfer. If no person holds an interest in the trust immediately after the GST, the transferor is treated as occupying the generation above the highest generation of any person in existence at the time of the GST who then occupies the highest generation level of any person who may subsequently hold an interest in the trust. See § 26.2612-1(e) for rules determining when a person has an interest in property held in trust.

(b) *Examples.* The following examples illustrate the provisions of this section: