A donor made large taxable gifts beginning in 1999 and a taxable gift in the current year.

Question:

A donor made large taxable gifts beginning in 1999 and a taxable gift in the current year. In the intervening years, the highest gift tax rates declined. In calculating the tax on taxable gifts of previous periods, which rate schedule is applicable: the one for the year in which the donor made the earlier gifts or the one for the current period? Discuss.