taxable event
(A)The term “taxable event” means any of the following: (i)The death of the transferor if the applicable retained interest conferring the distribution right is includible in the estate of the transferor. (ii)The transfer of such applicable retained interest. (iii)At the election of the taxpayer, the payment of any qualified payment after the period described in paragraph (2)(C), but only with respect to such payment. (B) (i)Subparagraph (A)(i) shall not apply to any interest includible in the gross estate of the transferor if a deduction with respect to such interest is allowable underor 2106(a)(3). (ii)A transfer to the spouse of the transferor shall not be treated as a taxable event under subparagraph (A)(ii) if such transfer does not result in a taxable gift by reason of— (I)any deduction allowed under section 2523, or the exclusion under section 2503(b), or (II)consideration for the transfer provided by the spouse. (iii)If an event is not treated as a taxable event by reason of this subparagraph, the transferee spouse or surviving spouse (as the case may be) shall be treated in the same manner as the transferor in applying this subsection with respect to the interest involved.