Are IRA distributions subject to Generation Skipping Tax (GST)?
Sec. 26.2611-1 Generation-skipping transfer defined.
A generation-skipping transfer (GST) is an event that is either a
direct skip, a taxable distribution, or a taxable termination. See Sec.
26.2612-1 for the definition of these terms. The determination as to
whether an event is a GST is made by reference to the most recent
transfer subject to the estate or gift tax. See Sec. 26.2652-1(a)(2)
for determining whether a transfer is subject to Federal estate or gift
tax.