104 STAT. 1388-500 PUBLIC LAW 101-508 —NOV. 5, 1990 "(C) any brother or sister of the individual, and "(D) any spouse of any individual described in subparagraph (B) or (C). "(3) ATTRIBUTION.—The rule of section 2701(e)(3)(A) shall apply for purposes of determining the interests held by any individual." (b) EXTENSION OF STATUTE OF LIMITATIONS.— Subsection (c) of section 6501 (relating to limitations on assessment and collection) is amended by adding at the end thereof the following new paragraph: " (9) GIFT TAX ON CERTAIN GIFTS NOT SHOWN ON RETURN. — If any gift of property the value of which is determined under section 2701 or 2702 (or any increase in taxable gifts required under section 2701(d)) is required to be shown on a return of tax imposed by chapter 12 (without regard to section 2503(b)), and is not shown on such return, any tax imposed by chapter 12 on such gift may be assessed, or a proceeding in court for the collection of such tax may be begun without assessment, at any time. The preceding sentence shall not apply to any item not shown as a gift on such return if such item is disclosed in such return, or in a statement attached to the return, in a manner adequate to apprise the Secretary of the nature of such item." (c) CONFORMING AMENDMENT.—The table of chapters for subtitle B is amended by adding at the end thereof the following item: " CHAPTEK 14. Special Valuation Rules. " 26 USC 2701 (d) STUDY.—The Secretary of the Treasury shall conduct a study note. Qf_ (1) the prevalence and tj^es of options and agreements used to distort the valuation of property for purposes of subtitle B of the Internal Revenue Code of 1986, and (2) other methods using discretionary rights to distort the value of property for such purposes. The Secretary shall, not later than December 31, 1992, report the results of such study, together with such legislative recommendations as the Secretary considers necessary, to the Committee on Finsmce of the Senate and the Committee on Ways and Means of the House of Representatives. 26 USC 2701 (e) EFFECTIVE DATES. — "°*®- (1) SUBSECTION (a). — (A) IN GENERAL.— The amendments made by subsection (a)- (i) to the extent such amendments relate to sections 2701 and 2702 of the Internal Revenue Code of 1986 (as added by such amendments), shall apply to transfers after October 8, 1990, (ii) to the extent such amendments relate to section 2703 of such Code (as so added), shall apply to— (I) agreements, options, rights, or restrictions entered into or granted after October 8, 1990, and (II) agreements, options, rights, or restrictions which are substantially modified after October 8, 1990, and (iii) to the extent such amendments relate to section 2704 of such C!ode (as so added), shall apply to restrictions or rights (or limitations on rights) created after October 8, 1990.