@Opus 17 , @jtax , @Anonymous_ just my two cents:
1. we are here discussing esoteric / nuanced concepts that while germane to the topic, does nothing to help the user in solving his/her issues --IMHO
2. the concepts (and use) of constructive and actual receipt / ownership may or may not be applicable to foreign tax situations -- e.g. there is no equivalent of trust in general in Mexican law ( Fideocommiso is a very narrowly applied equivalent )
3. One must be aware that while the transfer of assets to the inheritor(s) of physical asset and the valuation thereof have to follow IRS rules in the USA, same may or may not be true for situations in another country --e.g. mexican probate will do its own valuation of physical asset before distribution and will totally ignore any other valuation. Courts in India will apply indexing to the basis based on govt. inflation indices and not use independent valuation.
4. @Opus 17 was only trying ( i think ) to point out that there may be difference on the date when the donee/beneficiary is the owner vs. when all the paperwork is registered and finalized. In the USA the closing day is the transfer date and registration of the deed is just a formality ( usually within a few days ).
I hope I have poured enough oil on this issue
pk
