In the case of a taxable distribution, the tax imposed by section
2601 shall be paid by the transferee.
(2) Taxable termination
In the case of a taxable termination or a direct skip from a trust, the tax shall be paid by the trustee.
(3) Direct skip
In the case of a direct skip (other than a direct skip from a trust), the tax shall be paid by the transferor.
(b) Source of tax
Unless otherwise directed pursuant to the governing instrument by specific reference to the tax imposed by this chapter, the tax imposed by this chapter on a generation-skipping transfer shall be charged to the property constituting such transfer.
(c) Cross reference
For provisions making estate and gift tax provisions with respect to transferee liability, liens, and related matters applicable to the tax imposed by section
2601, see section
2661.