MODIFICATION OF CERTAIN VALUATION RULES.

SEC. 563. MODIFICATION OF CERTAIN VALUATION RULES. (a) Gifts for Which Gift Tax Return Filed or Deemed Allocation Made.—Paragraph (1) of section 2642(b) (relating to valuation rules, etc.) is amended to read as follows: “(1) Gifts for which gift tax return filed or deemed allocation made.—If the allocation of the GST exemption to any transfers of property is made on a gift tax return filed on or before the date prescribed by section 6075(b) for such transfer or is deemed to be made under section 2632 (b)(1) or (c)(1)— “(A) the value of such property for purposes of subsection (a) shall be its value as finally determined for purposes of chapter 12 (within the meaning of section 2001(f)(2)), or, in the case of an allocation deemed to have been made at the close of an estate tax inclusion period, its value at the time of the close of the estate tax inclusion period, and “(B) such allocation shall be effective on and after the date of such transfer, or, in the case of an allocation deemed to have been made at the close of an estate tax inclusion period, on and after the close of such estate tax inclusion period.”. (b) Transfers at Death.—Subparagraph (A) of section 2642(b)(2) is amended to read as follows: “(A) Transfers at death.—If property is transferred as a result of the death of the transferor, the value of such property for purposes of subsection (a) shall be its value as finally determined for purposes of chapter 11; except that, if the requirements prescribed by the Secretary respecting allocation of post-death changes in value are not met, the value of such property shall be determined as of the time of the distribution concerned.”.115 STAT. 91 (c) Effective Date.—The amendments made by this section shall apply to transfers subject to chapter 11 or 12 of the Internal Revenue Code of 1986 made after December 31, 2000.