SEC. __. ACCESSION SETTLEMENT; EXECUTOR WITHHOLDING; ACCESSION STAMP.

The estate's executor is the third-party settlement agent for the accession tax. At each distribution, the executor withholds 5% of the taxable accession, remits it, and files the recipient schedule that posts the receipt to the heir's lifetime accession ledger. Upon payment, the heir is issued an accession stamp: the certificate that perfects title to the inherited property, certifies its basis, and caps the heir's transferee liability at the value received. Transfer agents, brokerages, land registries, and courts shall require the stamp to retitle, transfer, or enforce ownership of inherited covered assets. An unstamped accession conveys no perfected title, carries the full undisclosed-covered-asset liability without the nonculpable cap, and tolls no limitation period. Heirs file individually only to claim credits or corrections.

(a) Executor as Settlement Agent.—
The executor, administrator, or other personal representative of an estate (in
this section, the "executor") shall act as the third-party settlement agent for
the accession tax with respect to every distribution of property from the
estate. A trustee, custodian, or other fiduciary making a distribution that
constitutes a taxable accession shall be treated as an executor for purposes of
this section with respect to that distribution.

(b) Withholding and Remittance.—

    (1) In general.—At the time of each distribution, the executor shall
        withhold from the property distributed (or collect from the recipient)
        an amount equal to the accession-tax rate applied to the taxable
        accession, determined after application of the recipient's remaining
        lifetime exemption as shown on the recipient schedule.

    (2) Remittance.—Amounts withheld shall be remitted to the Secretary not
        later than the due date prescribed by the Secretary, together with the
        recipient schedule described in subsection (c).

    (3) Illiquid distributions.—Where the property distributed is not readily
        divisible or liquid, the executor may satisfy paragraph (1) from other
        estate assets, from cash provided by the recipient, or under a
        deferred-payment agreement with the Secretary secured by a lien on the
        distributed property.

(c) Recipient Schedule; Lifetime Accession Ledger.—
With each remittance the executor shall file a schedule identifying each
recipient, the property distributed, its certified fair market value and basis,
the exemption applied, and the tax withheld. The Secretary shall post each
scheduled receipt to the recipient's lifetime accession ledger. Prior receipts
consume the lifetime exemption first; the taxable accession is determined on
the ledger, not annually.

(d) Accession Stamp.—

    (1) Issuance.—Upon receipt of the remittance and schedule, the Secretary
        shall issue to the recipient an accession stamp for the distributed
        property.

    (2) Effect.—The accession stamp—
        (A) perfects the recipient's title to the distributed property;
        (B) certifies the property's fair market value and basis as of the
            date of distribution for all subsequent federal tax purposes; and
        (C) caps the recipient's liability as a transferee, with respect to
            the estate from which the property was received, at the value
            received, as provided in the nonculpable-heir limitation of
            SEC. __. (UNDISCLOSED COVERED ASSETS).

    (3) Disclosure effect.—Issuance of the stamp constitutes adequate
        disclosure of the distributed property as to the recipient, and the
        applicable limitation periods begin on the date of issuance.

(e) Retitling Requirement.—
No transfer agent, brokerage, securities intermediary, land registry, recorder
of deeds, or court shall register, retitle, transfer, or enforce ownership of
an inherited covered asset absent presentation of the accession stamp (or a
determination by the Secretary that no stamp is required). Registration or
transfer in violation of this subsection is void as against the United States.

(f) Unstamped Accessions.—
An accession for which no stamp has been issued—

    (1) conveys no perfected title as against the United States;
    (2) constitutes an undisclosed covered asset in the hands of the
        recipient, carrying the full liability of SEC. __. (UNDISCLOSED
        COVERED ASSETS) without the nonculpable cap; and
    (3) tolls no limitation period.

(g) Executor Liability; Penalties.—
An executor who fails to withhold, remit, or file as required by this section
is personally liable for the tax not withheld, together with interest and the
penalties applicable to third-party withholding agents. A lien in favor of the
United States attaches to distributed property until the stamp issues. Willful
failure, false certification of value or basis, or structuring of
distributions to defeat withholding is punishable as provided for willful
failures by withholding agents, without limiting prosecution under any other
provision of law.

(h) Individual Filings.—
A recipient files individually under this section only to claim a credit
(including prepayment-overflow credits), a correction, or a refund. No annual
recipient return is otherwise required.

(i) Coordination.—
This section applies to accessions settled through a compliant executor
filing. Deemed accessions arising on re-establishment of United States tax
residence (inbound deemed accession) are charged at estate-equivalent rates
under the applicable section and are not eligible for the rate applicable to
executor-settled accessions.

The 5% rate is priced as a stamp: cheap enough that truthful filing dominates planning, real enough that the filing carries an assessable liability, a penalty base, a limitation period to toll, and the heir's purchased indemnity. Third-party withholding at the source plus title-gated compliance is the same mechanism that makes wage withholding near-evasion-proof — the executor remits, the stamp perfects title, and an unstamped inheritance is worth less than a stamped one to its own holder.