"These proposals, if enacted, would become effective for individuals dying after Dec. 31, 2021. This includes any transfers that apply to descendants who are two or more generations below the transferor, known as generation-skipping transfers (GSTs)."
In many cases, GST in essence would be retroactive.
“If a trust transfers property by gift or decantation to another trust in any calendar year after December 31, 2020, the transferor trust and the transferee trust shall be treated as a single applicable taxpayer for such calendar year.”
And don't forget to factor the Pochahontas tax. Note the difference of effective dates.
There is no escape! bwahaha!!