Proposed Regulation on Alternative Valuation Date
The IRS recently released proposed regulations REG-112196-07. The proposed regulations govern the electing of an alternate valuation date for an estate and would allow executors to elect to value an estate on the date six months following the decedent’s death. Any property transferred or disposed of during the six month period is valued as of the disposition date. If an interest’s value changes merely due to the lapse of time, then the interest is valued as of the decedent’s death. The proposed regulations also state that a post-death event will not result in a distribution, sale, exchange or other disposition of the property for alternate valuation date purposes if Congress has, by statute, deemed that a post-death event occurs on the decedent’s date of death.
For more information on REg-112196-07, see IRS Reissues Alternative Valuation Date Proposed Regulations, Journal of Accountancy, Nov. 17, 2011.
Special thanks to Jim Hillhouse (WealthCounsel) for bringing this article to my attention.