26 U.S. Code § 2624 - Valuation

prev | next
(a) General rule
Except as otherwise provided in this chapter, property shall be valued as of the time of the generation-skipping transfer.
(b) Alternate valuation and special use valuation elections apply to certain direct skips
In the case of any direct skip of property which is included in the transferor’s gross estate, the value of such property for purposes of this chapter shall be the same as its value for purposes of chapter 11 (determined with regard to sections 2032 and 2032A).
(c) Alternate valuation election permitted in the case of taxable terminations occurring at death
If 1 or more taxable terminations with respect to the same trust occur at the same time as and as a result of the death of an individual, an election may be made to value all of the property included in such terminations in accordance with section 2032.
(d) Reduction for consideration provided by transferee
For purposes of this chapter, the value of the property transferred shall be reduced by the amount of any consideration provided by the transferee.

Source

(Added Pub. L. 99–514, title XIV, § 1431(a),Oct. 22, 1986, 100 Stat. 2721.)
Effective Date

Section applicable to generation-skipping transfers (within the meaning of section 2611 of this title) made after Oct. 22, 1986, except as otherwise provided, see section 1433 ofPub. L. 99–514, set out as a note under section 2601 of this title.

Written determinations for this section

These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.

Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.

Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.

We truncate results at 20000 items. After that, you're on your own.

 

LII has no control over and does not endorse any external Internet site that contains links to or references LII.