Loopholes > Federal > Alternate Valuation and Special Use Valuation Election
DEDUCTION HIGH SAVINGS INVESTOR

Alternate Valuation and Special Use Valuation Election

IRC §2624

Allows the use of alternate valuation (IRC 2032) or special use valuation (IRC 2032A) for certain direct skips and taxable terminations occurring at death to reduce the taxable value of the property.

Eligibility

Available for direct skips included in a transferor's gross estate or taxable terminations occurring at the same time as an individual's death.

Frequently Asked Questions

Who is eligible for the Alternate Valuation and Special Use Valuation Election?

Available for direct skips included in a transferor's gross estate or taxable terminations occurring at the same time as an individual's death.

How does the Alternate Valuation and Special Use Valuation Election work?

Allows the use of alternate valuation (IRC 2032) or special use valuation (IRC 2032A) for certain direct skips and taxable terminations occurring at death to reduce the taxable value of the property.

What law authorizes the Alternate Valuation and Special Use Valuation Election?

The Alternate Valuation and Special Use Valuation Election is authorized under IRC §2624 of the Internal Revenue Code (Title 26, United States Code).

Statutory Text — IRC §2624

Source: Internal Revenue Code, Title 26, United States Code

§ 2624. Valuation(a) General ruleExcept 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 skipsIn 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 deathIf 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 trans­fereeFor purposes of this chapter, the value of the property transferred shall be reduced by the amount of any consideration provided by the transferee. (Added Pub. L. 99–514, title XIV, § 1431(a), Oct. 22, 1986, 100 Stat. 2721.) Statutory Notes and Related Subsidiaries Effective DateSection 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 of Pub. L. 99–514, set out as a note under section 2601 of this title.