springfieldspur
Level 1
01-29-2020
05:34 PM
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Any comments on the following fact pattern:
Decedent is a nonresident alien
Beneficiary is a nonresident alien
Stock certificates held by the decedent are all shares of US companies.
Because of the length of time before the inherited unclaimed property was discovered, the shares had been remitted to the State and the State had converted the shares to cash.
Question: is FMV determined upon the decedent's date of death, or following Cesanini, is FMV determined on the date of "undisputed posession." Moreover, since on the date of undisputed posession the beneficiary received cash -- so is the FMV on date of death irrelevant since the value of the cash is absolute (i.e. not subject to mark-to-market).