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On Sept. 16, 2024, Treasury released final regulations (final regs) under Internal Revenue Code Sections 1014(f) and 6035, which Congress added to the IRC via the Surface Transportation and Veterans Health Care Choice Improvement Act of 20151 way back on July 31, 2015. That law took effect the next day—Aug. 1, 2015.2 Temporary and proposed regulations (proposed regs) had been issued on March 6, 2016.
Collectively, these consistent basis rules have two different goals. IRC Section 1014(f) is relatively uncontroversial; it provides that the value of an asset set forth by an executor on an estate tax return, as accepted or revised by the Internal Revenue Service, will be the basis of that asset in the hands of the beneficiary (subject to cer...
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