Section 2624. Valuation (a) General rule

-Except  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 skips.-In 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 death.-If one  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 transferee.-For purposes
  of this chapter, the value of the property transferred shall be  reduced
  by the amount of any consideration provided by the transferee.