Part I. Rulings — Internal Revenue Bulletin 2009-20

Section 7520.—Valuation Tables

26 CFR 1.7520–1: Valuation of annuities unitrust in- terests, interests for life or terms of years, and remain- der or reversionary interests prior to May 1, 2009.

T.D. 9448

DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1, 20, and 25

Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final and temporary regulations.

SUMMARY: This document contains regulations relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. These regulations will affect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. These regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available. The text of the temporary regulations also serves as the text of the proposed regulations (REG–107845–08) set forth in the notice of proposed rulemaking on this subject elsewhere in this issue of the Bulletin.

DATES: Effective Date: These regulations are effective on May 1, 2009.

Applicability Date: These regulations apply on May 1, 2009.

FOR FURTHER INFORMATION CONTACT: Mayer R. Samuels, (202) 622–3090 (not a toll-free number).

SUPPLEMENTARY INFORMATION:

Background

This document contains amendments to the regulations revising certain tables used for the valuation of partial interests in property under section 7520 of the Internal Revenue Code of 1986 (Code) to reflect the most recent mortality experience available.

In General

Section 7520, effective for transfers for which the valuation date is after April 30, 1989, provides generally that the value of an annuity, an interest for life or a term of years, and a remainder or reversionary interest is to be determined under tables published by the Secretary by using an interest rate (rounded to the nearest two-tenths of one percent) equal to 120 percent of the Federal midterm rate in effect under section 1274(d)(1) for the month in which the valuation date falls. Section 7520(c)(3) directed the Secretary to issue tables not later than December 31, 1989, utilizing the then most recent mortality experience. Thereafter, the Secretary is directed to revise these tables not less frequently than once each 10 years to take into account the most recent mortality experience available as of the time of the revision.

These temporary regulations, REG–107845–08, incorporate revised Ta

ble S (Single Life Remainder Factors) and Table U(1) (Unitrust Single Life Remainder Factors), effective for transfers for which the valuation date is on or after May 1, 2009, based on data compiled from the 2000 census as set forth in Life Table 2000CM, and make conforming amendments to various sections to reflect the revised tables. At the same time, in the portions of these regulations that are final regulations, REG–105643–09, the current tables, effective for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, are moved to sections containing actuarial material for historical reference. Table B, Table D, Tables F(4.2) through F(14.0), Table J, and Table K, which are not based on mortality experience, are not changed. Internal Revenue Service Publications 1457 “Actuarial Val- uations Version 3A” (forthcoming 2009), 1458 “Actuarial Valuations Version 3B” (forthcoming 2009), and 1459 “Actuar- ial Valuations Version 3C” (forthcoming 2009) will contain a complete set of actuarial tables that include factors not contained in the temporary regulations (for example, annuity and life interest factors). These publications will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov .

The following chart summarizes the applicable interest rates and the citations to textual materials and tables for the various periods covered under the current regulations:

2009–20 I.R.B. 942 May 18, 2009

Cross Reference to Regulation Sections

Valuation

Period

Interest

Rate

Regulation

Section Table

Section 642 :

Valuation, in general - 1.642(c)–6

before 01/01/52 4% 1.642(c)–6A(a) 01/01/52 - 12/31/70 3.5% 1.642(c)–6A(b) 01/01/71 - 11/30/83 6% 1.642(c)–6A(c) 12/01/83 - 04/30/89 10% 1.642(c)–6A(d) Table G 05/01/89 - 04/30/99 §7520 1.642(c)–6A(e) Table S (5/1/89 - 4/30/99) 05/01/99 - 04/30/09 §7520 1.642(c)–6A(f) Table S (5/1/99 - 04/30/09) on or after 05/01/09 §7520 1.642(c)–6T(e) Table S (on or after 05/01/09)

Section 664 :

Valuation, in general - 1.664–4

before 01/01/52 4% 1.664–4A(a) 01/01/52 - 12/31/70 3.5% 1.664–4A(b) 01/01/71 - 11/30/83 6% 1.664–4A(c) 12/01/83 - 04/30/89 10% 1.664–4A(d) Table E, Table F(1) 05/01/89 - 04/30/99 §7520 1.664–4A(e) Table U(1) (5/1/89 - 4/30/99) 05/01/99 - 04/30/09 §7520 1.664–4A(f) Table U(1) (5/1/99 - 04/30/09 on or after 05/01/09 §7520 1.664–4T(e) Table U(1) (on or after 05/01/09 1.664–4(e) Table D and Tables F(4.2) - F(14.0)

Section 2031 :

Valuation, in general - 20.2031–7

before 01/01/52 4% 20.2031–7A(a) 01/01/52 - 12/31/70 3.5% 20.2031–7A(b) 01/01/71 - 11/30/83 6% 20.2031–7A(c) 12/01/83 - 04/30/89 10% 20.2031–7A(d) Table A, Table B, Table LN 05/01/89 - 04/30/99 §7520 20.2031–7A(e) Table S (5/1/89 - 4/30/99) and Life Table 80CNSMT 05/01/99 - 04/30/09 §7520 20.2031–7A(f) Table S (5/1/99 - 4/30/09) and Life Table 90 CM on or after 05/01/09 §7520 20.2031–7T(d) Table S (on or after 05/01/09) and Life Table 2000CM 20.2031–7(d) Table B, Table J, Table K

Section 2512:

Valuation, in general - 25.2512–5

before 01/01/52 4% 25.2512–5A(a) 01/01/52 - 12/31/70 3.5% 25.2512–5A(b) 01/01/71 - 11/30/83 6% 25.2512–5A(c) 12/01/83 - 04/30/89 10% 25.2512–5A(d) 05/01/89 - 04/30/99 §7520 25.2512–5A(e) 05/01/99 - 04/30/09 §7520 25.2512–5A(f) on or after 05/01/09 §7520 25.2512–5T(d)

donor may choose to determine the value of the gift (and/or any applicable charitable deduction) under tables based on either Life Table 90CM or Table 2000CM. Similarly, for estate tax purposes, if the decedent dies on or after May 1, 2009, but before July 1, 2009, the value of any interest (and/or any applicable charitable de

Effective Dates

These regulations are applicable in the case of annuities, interests for life or terms of years, and remainder or reversionary interests valued as of a date on or after May 1, 2009.

Transitional Rules

The regulations provide certain transitional rules intended to alleviate any adverse consequences resulting from the proposed regulatory change. For gift tax purposes, if the date of a transfer is on or after May 1, 2009, but before July 1, 2009, the

May 18, 2009 943 2009–20 I.R.B.

§1.170A–12T Valuation of a remainder interest in real property for contributions made after July 31, 1969 (temporary) .

(a) through (b)(1) [Reserved]. For further guidance, see §1.170A–12(a) through (b)(1).

(b)(2) Computation of depreciation fac- tor . If the valuation of the remainder interest in depreciable property is dependent upon the continuation of one life, a special factor must be used. The factor determined under this paragraph (b)(2) is carried to the fifth decimal place. The special factor is to be computed on the basis of the interest rate and life contingencies prescribed in §20.2031–7T (or for periods before May 1, 2009, §20.2031–7A) and on the assumption that the property depreciates on a straight-line basis over its estimated useful life. For transfers for which the valuation date is on or after May 1, 2009, special factors for determining the present value of a remainder interest following one life and an example describing the computation are contained in Internal Revenue Service Publication 1459, “Actuarial Valuations Ver- sion 3C” (2009). This publication will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov . For transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, special factors for determining the present value of a remainder interest following one life and an example describing the computation are contained in Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (7–99). For transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, special factors for determining the present value of a remainder interest following one life and an example describing the computation are contained in Internal Revenue Service Publication 1459, “Actuarial Values, Gamma Volume,” (8–89). These publications are no longer available for purchase from the Superintendent of Documents, United States Government Printing Office. However, they may be obtained by requesting a copy from: CC:PA:LPD:PR (IRS Publication 1459), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables

duction) may be determined in the discretion of the decedent’s executor under tables based on either Life Table 90CM or Table 2000CM. However, the section 7520 interest rate to be utilized is the appropriate rate for the month in which the valuation date occurs, subject to the following special rule for certain charitable transfers. Specifically, in accordance with this transitional rule and the rules contained in §§1.7520–2(a)(2), 20.7520–2(a)(2) and 25.7520–2(a)(2), in cases involving a charitable deduction, if the valuation date occurs on or after May 1, 2009, and before July 1, 2009, and the executor or donor elects under section 7520(a) to use the section 7520 interest rate for March 2009 or April 2009, then the mortality experience contained in 90CM must be used. If the executor or donor uses the section 7520 interest rate for May 2009 or for June 2009, then the tables based on either Table 90CM or Table 2000CM may be used. However, if the valuation date occurs after June 30, 2009, the executor or donor must use the new mortality experience contained in Table 2000CM even if the use of a prior month’s interest rate is elected under section 7520(a).

In addition, for estate tax purposes, the estate of a mentally incompetent decedent may elect to value the property interest included in the gross estate either under the mortality table and interest rate in effect at the time the decedent became mentally incompetent or under the mortality table and interest rate in effect on the decedent’s date of death if the decedent was under a mental incapacity that existed on May 1, 2009, and continued uninterrupted until the decedent’s death, or the decedent died within 90 days after regaining competency on or after May 1, 2009.

Special Analyses

It has been determined that this Treasury decision is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. For applicability of the Regulatory Flexibility Act, please refer to the cross-referenced notice of proposed rulemaking published elsewhere in this Bulletin. Pursuant to section 7805(f) of the Internal Revenue Code, these regulations have been submitted to the Chief Counsel for Advocacy

of the Small Business Administration for comment on its impact on small business.

Drafting Information

The principal author of these regulations is Mayer R. Samuels, Office of the Associate Chief Counsel (Passthroughs and Special Industries), IRS. However, other personnel from the IRS and Treasury Department participated in their development.

- - - -

Adoption of Amendments to the Regulations

Accordingly, 26 CFR parts 1, 20, and 25 are amended as follows:

PART 1—INCOME TAXES

Paragraph 1. The authority citation for part 1 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 1.170A–12T also issued under 26 U.S.C. 170(f)(4). Section 1.642(c)–6T also issued under 26 U.S.C. 642(c)(5). Section 1.664–4T also issued under 26 U.S.C. 664(a). Section 1.7520–1T also issued under 26 U.S.C. 7520(c)(2). Par. 2. Sections 1.170A–12 is amended by revising paragraphs (b)(2) and (b)(3) and adding paragraph (f) to read as follows:

§1.170A–12 Valuation of a remainder interest in real property for contributions made after July 31, 1969 .

- - - (b)(2) and (b)(3) [Reserved]. For further guidance, see §§1.170A–12T(b)(2) and (b)(3).
- - - (f) Effective/applicability date . This section applies to contributions made after July 31, 1969.

Par. 3. Section 1.170A–12T is added to read as follows:

2009–20 I.R.B. 944 May 18, 2009

under certain circumstances). Otherwise, in the case of the valuation of a remainder

Where:

interest following one life, the special fac- tor may be obtained through use of the following formula:

n=the estimated number of years of useful life, i=the applicable interest rate under section 7520 of the Internal Revenue Code, v=1 divided by the sum of 1 plus the applicable interest rate under section 7520 of the Internal Revenue Code, x=the age of the life tenant, and lx=number of persons living at age x as set forth in Table 2000CM of §20.2031–7T (or, for periods before May 1, 2009, the tables set forth under §20.2031–7A).

(d) and (e) [Reserved]. For further guidance, see §1.642(c)–6T(d) and (e).

(f) Effective/applicability dates . This section applies after April 30, 1999, and before May 1, 2009.

Par. 5. Section 1.642(c)–6T is added to read as follows:

§1.642(c)–6T Valuation of a remainder interest in property transferred to a pooled income fund (temporary) .

(a) through (c) [Reserved]. For further guidance, see §1.642(c)–6(a) through (c).

(d) Valuation . The present value of the remainder interest in property transferred to a pooled income fund on or after May 1, 2009, is determined under paragraph (e) of this section. The present value of the remainder interest in property transferred to a pooled income fund for which the valuation date is before May 1, 2009, is determined under the following sections:

(3) The following example illustrates the provisions of this paragraph (b): Exam- ple . A, who is 62, donates to Y University a remainder interest in a personal residence, consisting of a house and land, subject to a reserved life estate in A. At the time of the gift, the land has a value of $30,000 and the house has a value of $100,000 with an estimated useful life of 45 years, at the end of which period the value of the house is expected to be $20,000. The portion of the property considered to be depreciable is $80,000 (the value of the house ($100,000) less its expected value at the end of 45 years ($20,000)). The portion of the property considered to be nondepreciable is $50,000 (the value of the land at the time of the gift ($30,000) plus the expected value of the house at the end of 45 years ($20,000)). At the time of the gift, the interest rate prescribed under section 7520 is 8.4 percent. Based on an interest rate of 8.4 percent, the remainder factor for $1.00 prescribed in §20.2031–7T(d) for a person age 62 is 0.26534. The value of the nondepreciable remainder interest is $13,267.00 (0.26534 times $50,000). The

value of the depreciable remainder interest is $15,053.60 (0.18817, computed under the formula described in paragraph (b)(2) of this section, times $80,000). Therefore, the value of the remainder interest is $28,320.60.

(f) Effective/applicability date . Paragraphs (b)(2) and (b)(3) apply to all contributions made on or after May 1, 2009.

(g) Expiration date . Paragraphs (b)(2) and (b)(3) expire on or before May 1, 2012.

Par. 4. Section 1.642(c)–6 is amended as follows:

Paragraph (d) is removed.
Paragraph (e) is redesignated as paragraph (f) of §1.642(c)–6A.
New paragraphs (d) and (e) are added.
Paragraph (f) is revised. The revisions and addition read as follows:

§1.642(c)–6 Valuation of a remainder interest in property transferred to a pooled income fund .

Valuation Dates

After Before

Applicable Regulations

01–01–52 1.642(c)–6A(a) 12–31–51 01–01–71 1.642(c)–6A(b) 12–31–70 12–01–83 1.642(c)–6A(c) 11–30–83 05–01–89 1.642(c)–6A(d) 04–30–89 05–01–99 1.642(c)–6A(e) 04–30–99 05/01/09 1.642(c)–6A(f)

(e) Present value of the remainder in- terest in the case of transfers to pooled in-

come funds for which the valuation date is on or after May 1, 2009 —(1) In general .

In the case of transfers to pooled income funds for which the valuation date is on or

May 18, 2009 945 2009–20 I.R.B.

tion 7520 rates for the 3 calendar years immediately preceding the calendar year in which the transfer to the pooled income fund is made. The deemed rate of return for transfers to new pooled income funds is recomputed each calendar year using the monthly section 7520 rates for the 3-year period immediately preceding the calendar year in which each transfer to the fund is made until the fund has been in existence for 3 taxable years and can compute its highest rate of return for the 3 taxable years immediately preceding the taxable year in which the transfer of property to the fund is made in accordance with the rules set forth in the first sentence of paragraph (e)(3)(ii) of this section.

(5) Computation of value of remainder interest . (i) The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(6) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based (See §1.642(c)–6A for certain prior periods). The tables in paragraph (e)(6) of this section include factors for yearly rates of return from 0.2 to 14 percent. Many actuarial factors not contained in the tables in paragraph (e)(6) of this section are contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Valuations Version 3A” (2009). This publication will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov . For other situations, see §1.642(c)–6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor.

(ii) This paragraph (e)(5) may be illustrated by the following example:

Example . A, who is 54 years and 8 months, transfers $100,000 to a pooled income fund, and retains a life income interest in the property. The highest yearly rate of return earned by the fund for its 3 preceding taxable years is 9.47 percent. In Table S, the remainder factor opposite 55 years under 9.4 percent is .16192 and under 9.6 percent is .15755. The present value of the remainder interest is $16,039.00, computed as follows:

after May 1, 2009, the present value of a remainder interest is determined under this section. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). The present value of a remainder interest that is dependent on the termination of the life of one individual is computed by the use of Table S in paragraph (e)(6) of this section. For purposes of the computations under this section, the age of an individual is the age at the individual’s nearest birthday.

(2) Transitional rules for valuation of transfers to pooled income funds . (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 2009, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died on or after May 1, 2009, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency on or after May 1, 2009, the present value of a remainder interest is determined as if the valuation date with respect to the decedent’s gross estate is either before or after May 1, 2009, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a pooled income fund for which the valuation date is on or after May 1, 2009, and before July 1, 2009, the present value of the remainder interest under this section is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(f)(6), at the option of the donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (e)(2)(i) and (e)(2)(ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(f)(6), the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax

deductions claimed must be valued based on the same tables).

(3) Present value of a remainder inter- est . The present value of a remainder interest in property transferred to a pooled income fund is computed on the basis of—

(i) Life contingencies determined from the values of lx that are set forth in Table 2000CM in §20.2031–7T(d)(7) (see §20.2031–7A for certain prior periods); and

(ii) Discount at a rate of interest, compounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. For purposes of this paragraph (e), the yearly rate of return of a pooled income fund is determined as provided in §1.642(c)–6(c) unless the highest rate of return is deemed to be the rate described in paragraph (e)(4) of this section for funds in existence less than 3 taxable years. For purposes of this paragraph (e)(3)(ii), the first taxable year of a pooled income fund is considered a taxable year even though the taxable year consists of less than 12 months. However, appropriate adjustments must be made to annualize the rate of return earned by the fund for that period. Where it appears from the facts and circumstances that the highest yearly rate of return of the fund for the 3 taxable years immediately preceding the taxable year in which the transfer of property is made has been purposely manipulated to be substantially less than the rate of return that would otherwise be reasonably anticipated with the purpose of obtaining an excessive charitable deduction, that rate of return may not be used. In that case, the highest yearly rate of return of the fund is determined by treating the fund as a pooled income fund that has been in existence for less than 3 preceding taxable years.

(4) Pooled income funds in existence less than 3 taxable years . If a pooled income fund has been in existence less than 3 taxable years immediately preceding the taxable year in which the transfer is made to the fund and the transfer to the fund is made after April 30, 1989, the highest rate of return is deemed to be the interest rate (rounded to the nearest two-tenths of one percent) that is 1 percent less than the highest annual average of the monthly sec

2009–20 I.R.B. 946 May 18, 2009

Factor at 9.4 percent for age 55 . . . . . . . . . . . . . . . . . . . . . . .16192 Factor at 9.6 percent for age 55 . . . . . . . . . . . . . . . . . . . . . . .15755 Difference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .00437

Interpolation adjustment:

9.47% - 9.4% = x 0.2% .00437

x = .00153

Factor at 9.4 percent for age 55 . . . . . . . . . . . . . . . . . . . . . . .16192 Less: Interpolation adjustment . . . . . . . . . . . . . . . . . . . . . . .00153 Interpolated factor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16039

Present value of remainder interest:

($100,000 X .16039) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $16,039.00

(6) Actuarial tables . In the case of transfers for which the valuation date is on or after May 1, 2009, the present value of a

remainder interest dependent on the termination of one life in the case of a transfer

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

to a pooled income fund is determined by use of the following Table S:

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

0 .85816 .73751 .63478 .54723 .47252 .40872 .35416 .30747 .26745 .23313 1 .85889 .73863 .63604 .54844 .47355 .40948 .35459 .30752 .26711 .23239 2 .86054 .74145 .63968 .55260 .47802 .41409 .35922 .31209 .27155 .23664 3 .86221 .74433 .64339 .55687 .48263 .41887 .36404 .31685 .27619 .24112 4 .86390 .74725 .64716 .56121 .48733 .42374 .36898 .32175 .28098 .24575

5 .86560 .75018 .65097 .56561 .49209 .42871 .37401 .32675 .28588 .25050 6 .86731 .75314 .65482 .57006 .49692 .43375 .37913 .33186 .29090 .25538 7 .86902 .75611 .65868 .57454 .50180 .43885 .38432 .33704 .29601 .26035 8 .87073 .75909 .66258 .57907 .50674 .44403 .38960 .34233 .30122 .26544 9 .87246 .76209 .66651 .58364 .51173 .44928 .39497 .34771 .30654 .27064

10 .87419 .76511 .67046 .58826 .51679 .45459 .40042 .35319 .31197 .27596 11 .87592 .76814 .67445 .59291 .52190 .45998 .40596 .35876 .31750 .28139 12 .87766 .77119 .67845 .59761 .52706 .46544 .41157 .36443 .32313 .28693 13 .87939 .77424 .68247 .60232 .53225 .47094 .41723 .37015 .32884 .29255 14 .88112 .77728 .68649 .60704 .53746 .47646 .42293 .37592 .33460 .29823

15 .88284 .78031 .69050 .61176 .54267 .48199 .42865 .38172 .34038 .30394 16 .88455 .78333 .69449 .61647 .54788 .48752 .43437 .38752 .34619 .30968 17 .88625 .78633 .69848 .62117 .55309 .49307 .44012 .39336 .35203 .31546 18 .88795 .78933 .70246 .62588 .55830 .49863 .44589 .39923 .35791 .32129 19 .88964 .79232 .70644 .63059 .56354 .50422 .45170 .40514 .36385 .32719

20 .89132 .79532 .71044 .63534 .56882 .50987 .45757 .41114 .36987 .33317 21 .89301 .79832 .71445 .64010 .57413 .51555 .46350 .41719 .37597 .33925 22 .89470 .80133 .71847 .64488 .57947 .52129 .46948 .42332 .38216 .34541 23 .89639 .80434 .72251 .64970 .58486 .52708 .47554 .42954 .38844 .35168 24 .89808 .80737 .72658 .65456 .59031 .53295 .48169 .43586 .39484 .35809

25 .89978 .81042 .73068 .65947 .59583 .53890 .48795 .44230 .40137 .36464 26 .90149 .81349 .73482 .66443 .60141 .54494 .49430 .44886 .40804 .37134 27 .90320 .81657 .73899 .66944 .60707 .55107 .50076 .45554 .41484 .37819 28 .90492 .81968 .74319 .67450 .61278 .55728 .50733 .46233 .42178 .38520 29 .90665 .82279 .74741 .67960 .61856 .56356 .51398 .46924 .42884 .39233

30 .90837 .82591 .75165 .68473 .62438 .56990 .52070 .47623 .43601 .39959

May 18, 2009 947 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

31 .91010 .82904 .75592 .68989 .63024 .57631 .52751 .48333 .44329 .40698 32 .91182 .83218 .76020 .69509 .63616 .58278 .53440 .49052 .45068 .41449 33 .91355 .83532 .76449 .70031 .64212 .58931 .54137 .49780 .45818 .42213 34 .91527 .83847 .76880 .70556 .64811 .59589 .54839 .50516 .46578 .42988

35 .91700 .84162 .77312 .71082 .65414 .60253 .55549 .51261 .47347 .43774 36 .91872 .84477 .77744 .71611 .66021 .60921 .56266 .52014 .48127 .44572 37 .92043 .84792 .78178 .72142 .66631 .61594 .56989 .52774 .48916 .45381 38 .92215 .85107 .78613 .72675 .67244 .62272 .57718 .53544 .49715 .46201 39 .92386 .85422 .79048 .73210 .67860 .62955 .58453 .54320 .50523 .47032

40 .92557 .85736 .79483 .73746 .68479 .63641 .59194 .55104 .51340 .47873 41 .92727 .86050 .79918 .74283 .69100 .64331 .59940 .55894 .52165 .48724 42 .92896 .86364 .80354 .74820 .69723 .65024 .60690 .56691 .52998 .49585 43 .93065 .86677 .80789 .75359 .70348 .65721 .61447 .57495 .53840 .50457 44 .93234 .86990 .81225 .75899 .70976 .66422 .62208 .58305 .54690 .51338

45 .93402 .87302 .81660 .76439 .71605 .67125 .62973 .59122 .55547 .52228 46 .93569 .87613 .82095 .76980 .72236 .67832 .63743 .59945 .56413 .53129 47 .93735 .87924 .82530 .77521 .72867 .68541 .64517 .60773 .57286 .54037 48 .93901 .88233 .82964 .78062 .73501 .69253 .65295 .61606 .58166 .54955 49 .94065 .88541 .83397 .78604 .74135 .69967 .66077 .62446 .59053 .55882

50 .94229 .88849 .83830 .79145 .74771 .70684 .66864 .63292 .59949 .56819 51 .94393 .89156 .84263 .79688 .75409 .71404 .67655 .64143 .60852 .57766 52 .94556 .89462 .84695 .80230 .76048 .72127 .68450 .65001 .61763 .58722 53 .94717 .89767 .85126 .80772 .76687 .72852 .69249 .65863 .62680 .59687 54 .94878 .90070 .85555 .81313 .77326 .73577 .70050 .66730 .63603 .60658

55 .95037 .90371 .85983 .81853 .77964 .74302 .70851 .67598 .64530 .61635 56 .95195 .90670 .86406 .82388 .78599 .75024 .71651 .68465 .65457 .62613 57 .95351 .90965 .86827 .82920 .79230 .75744 .72448 .69332 .66384 .63593 58 .95505 .91257 .87243 .83447 .79857 .76459 .73242 .70195 .67309 .64573 59 .95657 .91546 .87655 .83970 .80479 .77170 .74033 .71057 .68233 .65553

60 .95807 .91832 .88064 .84490 .81098 .77879 .74822 .71918 .69158 .66534 61 .95955 .92115 .88469 .85005 .81713 .78584 .75608 .72776 .70081 .67515 62 .96101 .92395 .88869 .85515 .82323 .79283 .76388 .73630 .71001 .68494 63 .96245 .92670 .89265 .86020 .82926 .79977 .77164 .74479 .71917 .69470 64 .96387 .92942 .89655 .86518 .83524 .80665 .77933 .75323 .72828 .70443

65 .96527 .93210 .90040 .87011 .84116 .81346 .78697 .76162 .73735 .71411 66 .96665 .93476 .90423 .87502 .84706 .82027 .79461 .77002 .74645 .72385 67 .96802 .93739 .90803 .87990 .85292 .82705 .80223 .77841 .75554 .73359 68 .96937 .93999 .91179 .88472 .85874 .83378 .80980 .78676 .76461 .74331 69 .97070 .94255 .91549 .88949 .86449 .84044 .81731 .79504 .77362 .75299

70 .97200 .94506 .91914 .89419 .87016 .84702 .82473 .80326 .78256 .76260 71 .97328 .94754 .92273 .89882 .87577 .85353 .83209 .81140 .79143 .77215 72 .97453 .94997 .92626 .90338 .88129 .85996 .83935 .81945 .80021 .78162 73 .97576 .95234 .92972 .90785 .88671 .86627 .84651 .82739 .80888 .79098 74 .97695 .95466 .93310 .91223 .89202 .87247 .85353 .83518 .81741 .80019

75 .97811 .95692 .93638 .91649 .89720 .87851 .86039 .84281 .82577 .80923 76 .97924 .95910 .93957 .92063 .90224 .88440 .86708 .85026 .83393 .81807 77 .98033 .96122 .94267 .92465 .90715 .89013 .87360 .85753 .84191 .82671 78 .98138 .96327 .94567 .92855 .91190 .89571 .87995 .86461 .84968 .83515 79 .98239 .96526 .94857 .93233 .91652 .90112 .88611 .87149 .85725 .84337

80 .98337 .96717 .95138 .93598 .92098 .90635 .89208 .87817 .86460 .85135 81 .98431 .96901 .95408 .93951 .92529 .91141 .89786 .88463 .87172 .85910

2009–20 I.R.B. 948 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

82 .98521 .97077 .95667 .94290 .92944 .91629 .90344 .89088 .87861 .86660 83 .98608 .97247 .95917 .94616 .93343 .92099 .90882 .89691 .88526 .87385 84 .98691 .97409 .96156 .94928 .93727 .92551 .91399 .90271 .89166 .88084

85 .98770 .97565 .96384 .95228 .94094 .92984 .91895 .90828 .89782 .88757 86 .98845 .97713 .96602 .95514 .94446 .93398 .92371 .91362 .90373 .89402 87 .98917 .97854 .96810 .95786 .94781 .93794 .92825 .91873 .90939 .90021 88 .98985 .97988 .97008 .96046 .95100 .94171 .93258 .92361 .91479 .90612 89 .99049 .98115 .97196 .96292 .95404 .94530 .93671 .92826 .91994 .91176

90 .99110 .98235 .97373 .96526 .95691 .94871 .94062 .93267 .92484 .91713 91 .99168 .98348 .97541 .96747 .95964 .95193 .94434 .93686 .92949 .92223 92 .99222 .98455 .97700 .96955 .96222 .95498 .94785 .94083 .93390 .92707 93 .99273 .98556 .97849 .97152 .96464 .95786 .95117 .94457 .93806 .93163 94 .99321 .98651 .97989 .97337 .96692 .96057 .95429 .94810 .94199 .93595

95 .99366 .98739 .98121 .97510 .96907 .96312 .95724 .95143 .94569 .94002 96 .99408 .98822 .98244 .97673 .97108 .96551 .95999 .95454 .94916 .94384 97 .99447 .98900 .98359 .97825 .97297 .96774 .96258 .95747 .95242 .94742 98 .99483 .98973 .98467 .97967 .97473 .96984 .96500 .96021 .95547 .95078 99 .99518 .99040 .98568 .98101 .97638 .97180 .96727 .96278 .95834 .95394

100 .99549 .99103 .98661 .98224 .97791 .97362 .96937 .96516 .96100 .95687 101 .99579 .99162 .98750 .98340 .97935 .97534 .97136 .96742 .96351 .95964 102 .99607 .99217 .98831 .98448 .98068 .97692 .97319 .96950 .96583 .96220 103 .99634 .99271 .98911 .98553 .98199 .97848 .97500 .97155 .96812 .96473 104 .99659 .99320 .98984 .98651 .98320 .97992 .97666 .97344 .97023 .96705

105 .99683 .99369 .99056 .98747 .98439 .98134 .97830 .97530 .97231 .96934 106 .99713 .99429 .99146 .98865 .98586 .98309 .98033 .97760 .97488 .97218 107 .99747 .99496 .99246 .98998 .98751 .98506 .98262 .98020 .97779 .97539 108 .99800 .99602 .99404 .99208 .99012 .98818 .98624 .98431 .98240 .98049 109 .99900 .99801 .99702 .99603 .99505 .99407 .99310 .99213 .99116 .99020

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

0 .20365 .17830 .15648 .13767 .12144 .10741 .09528 .08476 .07564 .06772 1 .20251 .17677 .15458 .13542 .11885 .10451 .09209 .08131 .07194 .06379 2 .20656 .18060 .15817 .13877 .12197 .10740 .09476 .08376 .07420 .06586 3 .21084 .18466 .16200 .14236 .12533 .11054 .09767 .08647 .07670 .06817 4 .21527 .18888 .16600 .14613 .12887 .11385 .10076 .08935 .07938 .07066

5 .21984 .19324 .17013 .15004 .13255 .11730 .10399 .09237 .08220 .07329 6 .22454 .19773 .17440 .15408 .13636 .12089 .10736 .09553 .08515 .07605 7 .22933 .20233 .17879 .15824 .14030 .12460 .11085 .09880 .08822 .07892 8 .23425 .20705 .18330 .16254 .14436 .12844 .11447 .10221 .09142 .08193 9 .23930 .21191 .18795 .16697 .14857 .13243 .11824 .10576 .09476 .08507

10 .24446 .21689 .19273 .17153 .15292 .13655 .12214 .10945 .09824 .08835 11 .24975 .22200 .19764 .17623 .15740 .14081 .12619 .11328 .10187 .09177 12 .25515 .22724 .20268 .18107 .16202 .14521 .13037 .11724 .10563 .09533 13 .26064 .23256 .20782 .18600 .16674 .14972 .13466 .12132 .10949 .09900 14 .26620 .23796 .21303 .19101 .17154 .15430 .13903 .12547 .11344 .10273

May 18, 2009 949 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

15 .27179 .24340 .21829 .19607 .17639 .15894 .14344 .12968 .11743 .10652 16 .27742 .24887 .22358 .20117 .18128 .16361 .14790 .13391 .12145 .11034 17 .28309 .25439 .22893 .20632 .18622 .16834 .15241 .13821 .12554 .11421 18 .28881 .25997 .23434 .21154 .19123 .17314 .15699 .14258 .12969 .11815 19 .29461 .26563 .23983 .21684 .19633 .17803 .16167 .14703 .13393 .12218

20 .30050 .27139 .24543 .22226 .20156 .18304 .16646 .15161 .13829 .12633 21 .30649 .27726 .25114 .22779 .20689 .18817 .17138 .15631 .14277 .13060 22 .31259 .28323 .25697 .23344 .21235 .19342 .17642 .16114 .14739 .13500 23 .31879 .28934 .26293 .23923 .21795 .19882 .18161 .16612 .15215 .13955 24 .32515 .29559 .26904 .24519 .22372 .20440 .18699 .17128 .15710 .14429

25 .33166 .30201 .27534 .25133 .22969 .21018 .19256 .17665 .16226 .14924 26 .33833 .30861 .28182 .25767 .23586 .21616 .19835 .18224 .16764 .15440 27 .34517 .31538 .28849 .26420 .24224 .22236 .20436 .18804 .17324 .15980 28 .35217 .32233 .29535 .27093 .24882 .22877 .21058 .19407 .17907 .16542 29 .35932 .32944 .30237 .27784 .25558 .23537 .21701 .20031 .18511 .17126

30 .36661 .33670 .30956 .28492 .26253 .24216 .22362 .20674 .19135 .17730 31 .37403 .34411 .31691 .29217 .26965 .24914 .23044 .21338 .19779 .18355 32 .38160 .35167 .32442 .29960 .27697 .25631 .23745 .22022 .20445 .19002 33 .38930 .35939 .33211 .30721 .28447 .26368 .24467 .22727 .21133 .19671 34 .39713 .36724 .33993 .31497 .29213 .27123 .25207 .23451 .21839 .20360

35 .40509 .37523 .34792 .32290 .29998 .27896 .25967 .24195 .22567 .21070 36 .41318 .38337 .35606 .33100 .30800 .28688 .26746 .24961 .23317 .21803 37 .42139 .39165 .36435 .33927 .31621 .29499 .27546 .25746 .24087 .22557 38 .42974 .40008 .37281 .34771 .32460 .30330 .28366 .26554 .24880 .23334 39 .43821 .40864 .38141 .35631 .33316 .31179 .29205 .27381 .25694 .24133

40 .44679 .41734 .39016 .36507 .34189 .32046 .30064 .28229 .26529 .24954 41 .45549 .42616 .39906 .37399 .35080 .32932 .30942 .29097 .27386 .25797 42 .46430 .43511 .40809 .38307 .35987 .33836 .31840 .29986 .28264 .26662 43 .47324 .44421 .41729 .39232 .36913 .34760 .32758 .30897 .29165 .27552 44 .48229 .45343 .42663 .40172 .37857 .35702 .33697 .31829 .30088 .28465

45 .49144 .46277 .43611 .41128 .38817 .36663 .34655 .32782 .31033 .29400 46 .50072 .47225 .44574 .42101 .39796 .37644 .35634 .33757 .32002 .30360 47 .51009 .48185 .45550 .43089 .40791 .38642 .36633 .34753 .32992 .31343 48 .51958 .49158 .46540 .44093 .41803 .39660 .37652 .35770 .34006 .32351 49 .52917 .50143 .47545 .45113 .42833 .40696 .38691 .36810 .35043 .33383

50 .53888 .51141 .48566 .46150 .43883 .41754 .39754 .37874 .36106 .34442 51 .54871 .52153 .49602 .47204 .44951 .42832 .40838 .38961 .37194 .35528 52 .55865 .53179 .50653 .48276 .46038 .43931 .41945 .40073 .38307 .36641 53 .56869 .54217 .51718 .49363 .47143 .45050 .43074 .41208 .39446 .37781 54 .57882 .55265 .52796 .50465 .48265 .46186 .44222 .42364 .40607 .38945

55 .58902 .56322 .53884 .51579 .49400 .47338 .45387 .43540 .41789 .40131 56 .59926 .57383 .54978 .52701 .50544 .48501 .46565 .44729 .42987 .41335 57 .60951 .58449 .56078 .53830 .51698 .49675 .47755 .45932 .44201 .42555 58 .61978 .59517 .57182 .54964 .52858 .50858 .48956 .47147 .45427 .43790 59 .63007 .60589 .58290 .56105 .54027 .52050 .50167 .48375 .46668 .45041

60 .64039 .61665 .59405 .57254 .55205 .53253 .51392 .49617 .47925 .46310 61 .65072 .62743 .60524 .58409 .56390 .54465 .52627 .50872 .49196 .47595 62 .66104 .63822 .61645 .59566 .57581 .55683 .53870 .52136 .50478 .48892 63 .67133 .64900 .62766 .60726 .58774 .56907 .55120 .53409 .51770 .50200 64 .68161 .65977 .63887 .61887 .59970 .58134 .56375 .54688 .53071 .51519

65 .69186 .67053 .65009 .63049 .61170 .59367 .57637 .55976 .54381 .52849

2009–20 I.R.B. 950 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

66 .70216 .68136 .66140 .64223 .62383 .60615 .58916 .57283 .55713 .54203 67 .71250 .69224 .67277 .65405 .63605 .61874 .60208 .58605 .57062 .55575 68 .72283 .70312 .68416 .66590 .64833 .63140 .61509 .59938 .58423 .56963 69 .73312 .71398 .69553 .67776 .66062 .64409 .62815 .61277 .59793 .58360

70 .74335 .72479 .70688 .68959 .67291 .65680 .64124 .62621 .61168 .59764 71 .75353 .73556 .71819 .70141 .68519 .66951 .65434 .63968 .62549 .61176 72 .76364 .74626 .72945 .71318 .69744 .68220 .66745 .65317 .63933 .62593 73 .77365 .75686 .74061 .72487 .70962 .69484 .68051 .66662 .65315 .64009 74 .78350 .76733 .75164 .73643 .72167 .70735 .69346 .67997 .66688 .65417

75 .79318 .77761 .76249 .74781 .73355 .71971 .70625 .69318 .68048 .66813 76 .80266 .78769 .77314 .75899 .74524 .73187 .71886 .70621 .69390 .68192 77 .81194 .79756 .78358 .76997 .75672 .74382 .73127 .71904 .70713 .69553 78 .82100 .80722 .79380 .78072 .76798 .75556 .74346 .73166 .72016 .70894 79 .82984 .81664 .80378 .79124 .77900 .76706 .75542 .74405 .73296 .72213

80 .83843 .82582 .81351 .80149 .78976 .77830 .76711 .75618 .74550 .73507 81 .84678 .83474 .82298 .81148 .80025 .78927 .77853 .76803 .75777 .74773 82 .85487 .84339 .83217 .82119 .81045 .79994 .78966 .77959 .76974 .76009 83 .86269 .85177 .84107 .83060 .82035 .81030 .80047 .79083 .78139 .77214 84 .87024 .85986 .84968 .83970 .82993 .82035 .81095 .80174 .79271 .78385

85 .87751 .86765 .85798 .84849 .83919 .83005 .82110 .81230 .80368 .79521 86 .88450 .87515 .86597 .85696 .84811 .83942 .83089 .82251 .81428 .80619 87 .89119 .88234 .87363 .86508 .85668 .84843 .84031 .83234 .82450 .81679 88 .89760 .88922 .88099 .87289 .86492 .85708 .84938 .84180 .83434 .82700 89 .90372 .89580 .88801 .88034 .87280 .86537 .85806 .85087 .84378 .83681

90 .90954 .90207 .89471 .88746 .88032 .87329 .86637 .85954 .85282 .84620 91 .91508 .90803 .90109 .89424 .88750 .88085 .87429 .86783 .86146 .85518 92 .92033 .91369 .90714 .90068 .89432 .88803 .88184 .87572 .86969 .86374 93 .92530 .91904 .91287 .90678 .90078 .89484 .88899 .88321 .87751 .87188 94 .92999 .92411 .91830 .91256 .90690 .90130 .89578 .89032 .88493 .87961

95 .93442 .92889 .92342 .91802 .91269 .90741 .90220 .89706 .89197 .88694 96 .93858 .93338 .92824 .92316 .91813 .91316 .90825 .90340 .89859 .89385 97 .94248 .93759 .93276 .92798 .92325 .91857 .91395 .90937 .90484 .90036 98 .94614 .94155 .93701 .93252 .92807 .92367 .91931 .91500 .91073 .90650 99 .94959 .94528 .94101 .93679 .93260 .92846 .92436 .92030 .91628 .91229

100 .95278 .94874 .94473 .94075 .93682 .93292 .92906 .92523 .92144 .91769 101 .95581 .95201 .94824 .94451 .94081 .93715 .93352 .92992 .92635 .92281 102 .95860 .95503 .95149 .94798 .94450 .94105 .93763 .93424 .93088 .92754 103 .96136 .95802 .95470 .95142 .94816 .94492 .94171 .93853 .93538 .93224 104 .96390 .96077 .95766 .95458 .95152 .94848 .94547 .94248 .93951 .93657

105 .96640 .96347 .96057 .95769 .95483 .95199 .94917 .94637 .94359 .94083 106 .96950 .96684 .96420 .96157 .95896 .95636 .95379 .95123 .94868 .94616 107 .97301 .97064 .96829 .96595 .96362 .96131 .95901 .95672 .95445 .95219 108 .97859 .97670 .97482 .97295 .97109 .96923 .96739 .96555 .96373 .96191 109 .98924 .98828 .98733 .98638 .98544 .98450 .98356 .98263 .98170 .98077

May 18, 2009 951 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

0 .06083 .05483 .04959 .04501 .04101 .03749 .03441 .03170 .02931 .02721 1 .05668 .05049 .04507 .04034 .03618 .03254 .02934 .02652 .02403 .02183 2 .05858 .05222 .04665 .04178 .03750 .03373 .03042 .02750 .02492 .02264 3 .06072 .05420 .04848 .04346 .03904 .03516 .03173 .02871 .02603 .02366 4 .06303 .05634 .05046 .04530 .04075 .03674 .03319 .03006 .02729 .02483

5 .06547 .05861 .05258 .04726 .04258 .03844 .03478 .03153 .02866 .02610 6 .06805 .06102 .05482 .04935 .04453 .04026 .03647 .03312 .03014 .02749 7 .07074 .06353 .05717 .05155 .04658 .04217 .03826 .03479 .03171 .02895 8 .07356 .06617 .05964 .05386 .04875 .04421 .04017 .03658 .03338 .03053 9 .07651 .06895 .06225 .05631 .05105 .04637 .04220 .03849 .03518 .03222

10 .07960 .07185 .06499 .05889 .05347 .04865 .04435 .04052 .03709 .03402 11 .08283 .07490 .06786 .06160 .05603 .05106 .04663 .04267 .03912 .03594 12 .08620 .07808 .07087 .06444 .05871 .05360 .04903 .04494 .04127 .03798 13 .08967 .08137 .07397 .06738 .06149 .05623 .05152 .04729 .04351 .04010 14 .09321 .08472 .07715 .07038 .06433 .05892 .05406 .04971 .04579 .04227

15 .09680 .08812 .08036 .07342 .06721 .06164 .05664 .05214 .04810 .04445 16 .10041 .09154 .08360 .07649 .07011 .06438 .05923 .05459 .05041 .04664 17 .10409 .09502 .08689 .07960 .07305 .06716 .06185 .05707 .05276 .04886 18 .10782 .09855 .09024 .08276 .07604 .06998 .06452 .05959 .05514 .05111 19 .11164 .10217 .09366 .08600 .07910 .07288 .06726 .06218 .05758 .05341

20 .11559 .10592 .09721 .08937 .08228 .07589 .07010 .06487 .06012 .05582 21 .11965 .10977 .10087 .09283 .08557 .07900 .07305 .06765 .06276 .05831 22 .12383 .11376 .10465 .09642 .08897 .08223 .07610 .07055 .06550 .06090 23 .12817 .11789 .10859 .10016 .09252 .08559 .07930 .07358 .06837 .06363 24 .13270 .12221 .11270 .10408 .09625 .08914 .08267 .07678 .07141 .06651

25 .13744 .12674 .11703 .10821 .10019 .09289 .08625 .08018 .07465 .06960 26 .14239 .13149 .12158 .11256 .10435 .09686 .09003 .08380 .07810 .07288 27 .14758 .13647 .12636 .11714 .10873 .10106 .09405 .08764 .08177 .07639 28 .15300 .14169 .13137 .12195 .11335 .10549 .09829 .09171 .08567 .08012 29 .15864 .14712 .13660 .12698 .11819 .11013 .10275 .09598 .08977 .08406

30 .16448 .15275 .14203 .13222 .12323 .11498 .10742 .10047 .09408 .08820 31 .17053 .15861 .14769 .13768 .12849 .12006 .11230 .10517 .09860 .09255 32 .17680 .16468 .15357 .14336 .13398 .12535 .11741 .11009 .10335 .09712 33 .18330 .17099 .15968 .14927 .13970 .13088 .12275 .11525 .10832 .10192 34 .19000 .17750 .16599 .15539 .14562 .13661 .12829 .12061 .11350 .10693

35 .19692 .18423 .17253 .16174 .15178 .14258 .13408 .12621 .11892 .11217 36 .20407 .19119 .17931 .16833 .15818 .14879 .14009 .13204 .12457 .11764 37 .21144 .19838 .18631 .17515 .16481 .15523 .14635 .13811 .13046 .12335 38 .21904 .20582 .19357 .18222 .17170 .16193 .15287 .14444 .13661 .12932 39 .22687 .21348 .20105 .18952 .17882 .16887 .15962 .15102 .14300 .13554

40 .23493 .22137 .20878 .19707 .18619 .17606 .16663 .15784 .14965 .14201 41 .24322 .22950 .21674 .20487 .19381 .18350 .17390 .16493 .15656 .14873 42 .25173 .23786 .22494 .21290 .20168 .19120 .18141 .17227 .16372 .15572 43 .26049 .24648 .23342 .22122 .20982 .19918 .18922 .17990 .17118 .16301 44 .26950 .25535 .24214 .22979 .21824 .20742 .19730 .18781 .17892 .17057

45 .27874 .26447 .25112 .23862 .22692 .21595 .20566 .19600 .18694 .17843 46 .28824 .27385 .26038 .24774 .23589 .22476 .21431 .20450 .19527 .18659 47 .29798 .28349 .26989 .25712 .24513 .23386 .22326 .21328 .20390 .19505 48 .30797 .29338 .27967 .26678 .25466 .24325 .23250 .22238 .21283 .20383 49 .31822 .30355 .28974 .27674 .26449 .25294 .24206 .23179 .22210 .21294

2009–20 I.R.B. 952 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

50 .32876 .31401 .30011 .28701 .27465 .26298 .25196 .24156 .23172 .22242 51 .33958 .32477 .31079 .29759 .28513 .27335 .26221 .25168 .24170 .23226 52 .35068 .33582 .32178 .30851 .29595 .28407 .27282 .26216 .25206 .24249 53 .36206 .34717 .33308 .31974 .30710 .29513 .28378 .27301 .26279 .25309 54 .37371 .35880 .34467 .33127 .31857 .30651 .29507 .28420 .27388 .26406

55 .38559 .37067 .35652 .34308 .33032 .31820 .30668 .29572 .28529 .27537 56 .39765 .38275 .36859 .35512 .34232 .33014 .31855 .30751 .29699 .28697 57 .40990 .39502 .38086 .36739 .35455 .34233 .33068 .31957 .30898 .29887 58 .42231 .40747 .39333 .37985 .36700 .35474 .34304 .33188 .32121 .31103 59 .43490 .42011 .40600 .39253 .37968 .36740 .35567 .34446 .33374 .32348

60 .44768 .43296 .41890 .40546 .39261 .38033 .36858 .35733 .34656 .33625 61 .46064 .44600 .43200 .41860 .40578 .39351 .38175 .37048 .35968 .34933 62 .47373 .45920 .44527 .43194 .41915 .40690 .39514 .38387 .37305 .36267 63 .48696 .47253 .45870 .44544 .43271 .42049 .40876 .39749 .38666 .37625 64 .50030 .48601 .47229 .45911 .44645 .43428 .42258 .41133 .40051 .39010

65 .51377 .49963 .48603 .47295 .46037 .44827 .43662 .42540 .41460 .40420 66 .52750 .51352 .50007 .48711 .47464 .46262 .45103 .43987 .42911 .41872 67 .54144 .52765 .51436 .50154 .48919 .47727 .46578 .45468 .44397 .43363 68 .55554 .54196 .52885 .51619 .50398 .49218 .48079 .46978 .45915 .44887 69 .56976 .55640 .54349 .53102 .51896 .50731 .49603 .48513 .47458 .46438

70 .58407 .57095 .55826 .54598 .53410 .52260 .51147 .50069 .49025 .48013 71 .59848 .58561 .57316 .56109 .54940 .53808 .52710 .51646 .50615 .49614 72 .61294 .60035 .58815 .57632 .56484 .55371 .54291 .53243 .52225 .51237 73 .62741 .61512 .60318 .59160 .58035 .56943 .55882 .54851 .53849 .52876 74 .64183 .62983 .61818 .60686 .59586 .58516 .57476 .56464 .55480 .54523

75 .65612 .64444 .63309 .62204 .61129 .60083 .59065 .58074 .57109 .56169 76 .67026 .65891 .64786 .63710 .62661 .61640 .60646 .59676 .58731 .57810 77 .68423 .67321 .66248 .65201 .64181 .63186 .62215 .61269 .60345 .59444 78 .69800 .68733 .67692 .66676 .65684 .64717 .63772 .62849 .61948 .61068 79 .71156 .70124 .69116 .68132 .67170 .66230 .65312 .64414 .63537 .62680

80 .72487 .71490 .70516 .69563 .68632 .67721 .66830 .65959 .65106 .64272 81 .73791 .72830 .71890 .70970 .70069 .69188 .68325 .67481 .66654 .65844 82 .75065 .74140 .73235 .72348 .71479 .70628 .69794 .68977 .68176 .67391 83 .76308 .75419 .74548 .73695 .72858 .72037 .71232 .70443 .69669 .68909 84 .77516 .76664 .75828 .75008 .74203 .73413 .72638 .71877 .71130 .70396

85 .78689 .77873 .77072 .76285 .75512 .74753 .74008 .73275 .72556 .71849 86 .79825 .79044 .78278 .77524 .76783 .76055 .75340 .74636 .73944 .73264 87 .80921 .80176 .79443 .78722 .78014 .77316 .76630 .75956 .75292 .74638 88 .81978 .81268 .80569 .79880 .79203 .78536 .77880 .77234 .76598 .75971 89 .82994 .82317 .81651 .80995 .80349 .79712 .79085 .78467 .77859 .77259

90 .83967 .83324 .82690 .82065 .81450 .80843 .80244 .79655 .79073 .78500 91 .84898 .84288 .83685 .83091 .82505 .81928 .81358 .80795 .80241 .79693 92 .85787 .85208 .84636 .84072 .83515 .82966 .82423 .81888 .81360 .80838 93 .86632 .86083 .85541 .85006 .84477 .83955 .83440 .82931 .82428 .81931 94 .87435 .86915 .86402 .85894 .85393 .84898 .84409 .83925 .83447 .82975

95 .88197 .87705 .87219 .86739 .86265 .85795 .85331 .84872 .84419 .83970 96 .88915 .88451 .87991 .87537 .87088 .86643 .86203 .85768 .85338 .84912 97 .89593 .89154 .88720 .88290 .87865 .87444 .87028 .86616 .86208 .85804 98 .90232 .89818 .89408 .89002 .88600 .88202 .87808 .87418 .87031 .86649 99 .90835 .90444 .90057 .89674 .89294 .88918 .88546 .88177 .87811 .87449

100 .91397 .91028 .90663 .90301 .89942 .89587 .89234 .88885 .88539 .88196

May 18, 2009 953 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

101 .91930 .91583 .91238 .90897 .90558 .90223 .89890 .89560 .89233 .88908 102 .92424 .92096 .91771 .91448 .91128 .90811 .90496 .90184 .89875 .89568 103 .92914 .92605 .92300 .91996 .91695 .91397 .91100 .90806 .90514 .90225 104 .93364 .93074 .92786 .92501 .92217 .91935 .91656 .91379 .91103 .90830

105 .93809 .93537 .93266 .92998 .92731 .92467 .92204 .91943 .91683 .91426 106 .94365 .94115 .93867 .93621 .93376 .93133 .92892 .92651 .92413 .92176 107 .94994 .94771 .94549 .94328 .94108 .93890 .93673 .93457 .93242 .93028 108 .96010 .95830 .95651 .95472 .95295 .95118 .94942 .94767 .94593 .94420 109 .97985 .97893 .97801 .97710 .97619 .97529 .97438 .97348 .97259 .97170

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

0 .02534 .02370 .02223 .02093 .01978 .01874 .01782 .01699 .01625 .01559 1 .01989 .01817 .01664 .01528 .01406 .01298 .01202 .01115 .01037 .00967 2 .02061 .01882 .01722 .01580 .01454 .01340 .01239 .01148 .01066 .00993 3 .02156 .01969 .01802 .01654 .01521 .01403 .01297 .01201 .01115 .01038 4 .02264 .02069 .01896 .01741 .01602 .01478 .01367 .01267 .01176 .01095

5 .02383 .02180 .01999 .01838 .01693 .01563 .01446 .01341 .01246 .01161 6 .02512 .02301 .02113 .01944 .01793 .01657 .01535 .01424 .01325 .01235 7 .02650 .02430 .02234 .02058 .01900 .01758 .01630 .01514 .01410 .01315 8 .02798 .02570 .02365 .02182 .02017 .01868 .01734 .01613 .01503 .01404 9 .02957 .02720 .02507 .02316 .02143 .01988 .01848 .01721 .01606 .01502

10 .03128 .02881 .02659 .02460 .02280 .02118 .01971 .01838 .01718 .01608 11 .03309 .03053 .02823 .02615 .02428 .02258 .02105 .01966 .01839 .01725 12 .03503 .03237 .02997 .02781 .02585 .02408 .02248 .02103 .01971 .01850 13 .03704 .03428 .03179 .02954 .02750 .02565 .02398 .02246 .02108 .01982 14 .03909 .03623 .03364 .03130 .02918 .02726 .02551 .02392 .02248 .02116

15 .04117 .03820 .03551 .03308 .03087 .02886 .02704 .02538 .02387 .02249 16 .04324 .04016 .03737 .03484 .03254 .03046 .02855 .02682 .02524 .02379 17 .04533 .04214 .03924 .03661 .03422 .03205 .03007 .02826 .02661 .02509 18 .04746 .04415 .04114 .03841 .03592 .03366 .03159 .02970 .02798 .02639 19 .04963 .04620 .04309 .04025 .03766 .03530 .03315 .03117 .02937 .02772

20 .05191 .04835 .04512 .04217 .03948 .03702 .03478 .03272 .03083 .02910 21 .05427 .05058 .04723 .04416 .04137 .03881 .03647 .03432 .03235 .03054 22 .05672 .05291 .04943 .04625 .04334 .04067 .03823 .03599 .03394 .03205 23 .05930 .05535 .05174 .04844 .04542 .04265 .04010 .03777 .03562 .03364 24 .06204 .05795 .05421 .05078 .04764 .04476 .04211 .03967 .03743 .03536

25 .06497 .06074 .05687 .05331 .05005 .04705 .04429 .04174 .03940 .03724 26 .06811 .06373 .05972 .05603 .05264 .04952 .04665 .04400 .04155 .03929 27 .07146 .06694 .06278 .05895 .05543 .05219 .04920 .04644 .04389 .04153 28 .07503 .07036 .06605 .06209 .05844 .05507 .05196 .04908 .04642 .04396 29 .07881 .07398 .06953 .06542 .06163 .05814 .05490 .05191 .04913 .04656

30 .08279 .07780 .07319 .06894 .06502 .06138 .05802 .05491 .05202 .04933 31 .08697 .08182 .07707 .07267 .06860 .06483 .06134 .05810 .05509 .05229 32 .09137 .08606 .08115 .07660 .07239 .06848 .06485 .06148 .05835 .05543 33 .09601 .09053 .08546 .08075 .07639 .07234 .06858 .06508 .06182 .05878

2009–20 I.R.B. 954 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

34 .10084 .09520 .08996 .08511 .08059 .07640 .07249 .06886 .06547 .06231

35 .10590 .10009 .09470 .08968 .08501 .08067 .07662 .07285 .06933 .06605 36 .11120 .10522 .09966 .09448 .08966 .08517 .08098 .07706 .07341 .06999 37 .11674 .11059 .10486 .09952 .09454 .08990 .08556 .08150 .07771 .07416 38 .12254 .11621 .11032 .10481 .09968 .09487 .09039 .08618 .08225 .07856 39 .12857 .12208 .11601 .11035 .10505 .10009 .09545 .09110 .08702 .08320

40 .13487 .12820 .12196 .11613 .11067 .10555 .10076 .09626 .09204 .08807 41 .14142 .13458 .12817 .12217 .11655 .11127 .10632 .10167 .09730 .09319 42 .14823 .14122 .13464 .12848 .12269 .11725 .11214 .10734 .10282 .09856 43 .15535 .14816 .14141 .13508 .12913 .12353 .11826 .11330 .10863 .10422 44 .16274 .15538 .14847 .14196 .13585 .13008 .12466 .11954 .11472 .11016

45 .17042 .16290 .15581 .14914 .14286 .13694 .13135 .12608 .12110 .11640 46 .17842 .17073 .16348 .15664 .15020 .14411 .13836 .13293 .12780 .12294 47 .18672 .17886 .17145 .16445 .15784 .15159 .14568 .14010 .13481 .12980 48 .19534 .18732 .17974 .17258 .16581 .15940 .15334 .14759 .14215 .13699 49 .20429 .19612 .18838 .18106 .17413 .16757 .16134 .15544 .14984 .14453

50 .21362 .20529 .19740 .18993 .18284 .17612 .16974 .16368 .15793 .15247 51 .22332 .21484 .20680 .19917 .19194 .18506 .17853 .17232 .16642 .16080 52 .23341 .22479 .21660 .20883 .20144 .19442 .18774 .18138 .17533 .16957 53 .24388 .23513 .22681 .21889 .21136 .20419 .19737 .19087 .18467 .17876 54 .25473 .24585 .23739 .22935 .22168 .21437 .20741 .20076 .19442 .18837

55 .26593 .25693 .24835 .24017 .23238 .22494 .21784 .21105 .20458 .19838 56 .27742 .26831 .25962 .25132 .24340 .23583 .22860 .22169 .21508 .20875 57 .28922 .28001 .27121 .26280 .25476 .24707 .23971 .23267 .22593 .21947 58 .30129 .29199 .28309 .27457 .26642 .25862 .25114 .24398 .23712 .23053 59 .31367 .30428 .29529 .28667 .27842 .27051 .26293 .25565 .24867 .24197

60 .32638 .31691 .30784 .29914 .29079 .28278 .27509 .26771 .26062 .25380 61 .33940 .32987 .32073 .31195 .30352 .29542 .28763 .28015 .27295 .26603 62 .35269 .34311 .33391 .32506 .31656 .30837 .30050 .29293 .28564 .27862 63 .36625 .35663 .34738 .33847 .32990 .32165 .31370 .30604 .29867 .29155 64 .38007 .37043 .36113 .35218 .34356 .33524 .32723 .31950 .31204 .30484

65 .39417 .38451 .37519 .36620 .35753 .34917 .34110 .33330 .32577 .31850 66 .40871 .39905 .38972 .38071 .37201 .36361 .35550 .34765 .34006 .33273 67 .42365 .41400 .40468 .39567 .38696 .37853 .37038 .36250 .35487 .34749 68 .43892 .42931 .42001 .41101 .40230 .39387 .38570 .37780 .37014 .36272 69 .45450 .44493 .43567 .42670 .41800 .40958 .40141 .39350 .38582 .37837

70 .47033 .46083 .45162 .44269 .43403 .42563 .41748 .40957 .40189 .39443 71 .48644 .47702 .46788 .45901 .45040 .44203 .43391 .42602 .41835 .41090 72 .50278 .49347 .48441 .47562 .46707 .45877 .45069 .44284 .43520 .42776 73 .51930 .51010 .50115 .49245 .48399 .47575 .46774 .45994 .45234 .44494 74 .53591 .52684 .51802 .50943 .50106 .49291 .48497 .47724 .46970 .46235

75 .55253 .54361 .53492 .52645 .51820 .51015 .50230 .49465 .48719 .47991 76 .56912 .56036 .55182 .54349 .53536 .52742 .51968 .51213 .50475 .49754 77 .58565 .57706 .56868 .56050 .55251 .54471 .53708 .52964 .52236 .51525 78 .60209 .59369 .58549 .57747 .56963 .56197 .55448 .54715 .53999 .53298 79 .61841 .61021 .60219 .59435 .58668 .57917 .57182 .56463 .55760 .55071

80 .63456 .62657 .61875 .61109 .60359 .59625 .58906 .58202 .57512 .56836 81 .65050 .64273 .63512 .62766 .62034 .61318 .60616 .59927 .59252 .58590 82 .66621 .65867 .65127 .64401 .63690 .62992 .62308 .61636 .60977 .60330 83 .68164 .67433 .66716 .66012 .65321 .64642 .63976 .63322 .62680 .62050

May 18, 2009 955 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

84 .69676 .68969 .68275 .67593 .66923 .66265 .65618 .64983 .64358 .63745

85 .71154 .70472 .69801 .69141 .68493 .67856 .67229 .66613 .66007 .65412 86 .72595 .71937 .71290 .70654 .70028 .69412 .68806 .68210 .67623 .67046 87 .73995 .73362 .72740 .72127 .71523 .70929 .70344 .69768 .69201 .68642 88 .75354 .74746 .74148 .73558 .72978 .72406 .71842 .71287 .70739 .70200 89 .76668 .76085 .75511 .74945 .74387 .73837 .73295 .72761 .72234 .71714

90 .77934 .77377 .76827 .76284 .75749 .75222 .74701 .74188 .73681 .73181 91 .79153 .78620 .78094 .77575 .77063 .76558 .76059 .75566 .75080 .74600 92 .80323 .79814 .79312 .78816 .78326 .77843 .77365 .76894 .76428 .75967 93 .81440 .80956 .80477 .80004 .79536 .79074 .78618 .78166 .77721 .77280 94 .82508 .82047 .81591 .81140 .80694 .80253 .79817 .79387 .78961 .78539

95 .83526 .83088 .82654 .82225 .81800 .81380 .80965 .80554 .80148 .79746 96 .84491 .84074 .83662 .83254 .82850 .82450 .82055 .81663 .81276 .80892 97 .85405 .85009 .84617 .84230 .83846 .83466 .83089 .82717 .82348 .81982 98 .86270 .85895 .85523 .85155 .84791 .84430 .84072 .83718 .83367 .83019 99 .87090 .86735 .86382 .86033 .85687 .85345 .85005 .84668 .84335 .84004

100 .87856 .87519 .87185 .86854 .86526 .86201 .85878 .85559 .85242 .84927 101 .88587 .88268 .87952 .87638 .87327 .87019 .86713 .86409 .86109 .85810 102 .89263 .88961 .88662 .88364 .88069 .87777 .87487 .87199 .86913 .86629 103 .89938 .89653 .89370 .89089 .88810 .88534 .88259 .87987 .87717 .87448 104 .90558 .90289 .90021 .89756 .89492 .89231 .88971 .88713 .88456 .88202

105 .91170 .90916 .90664 .90413 .90164 .89917 .89672 .89428 .89186 .88945 106 .91940 .91706 .91474 .91242 .91013 .90784 .90558 .90332 .90108 .89885 107 .92816 .92605 .92395 .92186 .91978 .91772 .91567 .91362 .91159 .90957 108 .94247 .94075 .93904 .93734 .93565 .93396 .93229 .93062 .92895 .92730 109 .97081 .96992 .96904 .96816 .96729 .96642 .96555 .96468 .96382 .96296

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

0 .01498 .01444 .01395 .01351 .01310 .01273 .01240 .01209 .01181 .01155 1 .00904 .00847 .00796 .00749 .00707 .00668 .00633 .00601 .00572 .00545 2 .00926 .00866 .00812 .00763 .00718 .00677 .00640 .00606 .00575 .00547 3 .00968 .00905 .00848 .00796 .00748 .00705 .00666 .00630 .00597 .00567 4 .01021 .00955 .00894 .00839 .00789 .00744 .00702 .00664 .00629 .00597

5 .01083 .01013 .00949 .00891 .00839 .00790 .00746 .00706 .00669 .00635 6 .01153 .01080 .01012 .00951 .00895 .00844 .00798 .00755 .00715 .00679 7 .01229 .01151 .01081 .01016 .00957 .00903 .00854 .00808 .00767 .00728 8 .01314 .01232 .01157 .01089 .01026 .00969 .00917 .00869 .00825 .00784 9 .01407 .01321 .01242 .01170 .01104 .01044 .00989 .00938 .00891 .00848

10 .01509 .01418 .01335 .01259 .01190 .01126 .01068 .01014 .00965 .00919 11 .01620 .01525 .01437 .01358 .01285 .01218 .01156 .01099 .01047 .00998 12 .01740 .01640 .01549 .01465 .01388 .01317 .01252 .01192 .01137 .01086 13 .01867 .01762 .01665 .01577 .01496 .01422 .01353 .01290 .01231 .01177 14 .01995 .01885 .01784 .01691 .01606 .01527 .01455 .01389 .01327 .01270

15 .02123 .02007 .01901 .01803 .01714 .01632 .01556 .01485 .01420 .01360 16 .02247 .02126 .02015 .01913 .01818 .01732 .01652 .01578 .01509 .01446

2009–20 I.R.B. 956 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

17 .02371 .02244 .02127 .02020 .01921 .01830 .01746 .01668 .01596 .01529 18 .02494 .02361 .02239 .02126 .02022 .01926 .01838 .01756 .01680 .01610 19 .02620 .02480 .02352 .02234 .02125 .02024 .01931 .01844 .01764 .01690

20 .02751 .02605 .02471 .02346 .02232 .02126 .02028 .01937 .01853 .01775 21 .02888 .02735 .02593 .02463 .02343 .02231 .02128 .02032 .01944 .01861 22 .03030 .02870 .02722 .02585 .02458 .02341 .02233 .02132 .02038 .01951 23 .03181 .03013 .02858 .02714 .02581 .02458 .02344 .02237 .02139 .02047 24 .03345 .03169 .03006 .02855 .02715 .02586 .02465 .02353 .02249 .02152

25 .03524 .03340 .03169 .03010 .02863 .02727 .02600 .02482 .02373 .02270 26 .03720 .03527 .03348 .03181 .03027 .02884 .02750 .02626 .02510 .02402 27 .03934 .03732 .03544 .03370 .03208 .03057 .02916 .02786 .02664 .02549 28 .04167 .03955 .03759 .03576 .03406 .03247 .03099 .02962 .02833 .02713 29 .04417 .04196 .03990 .03798 .03619 .03453 .03298 .03153 .03017 .02890

30 .04684 .04452 .04237 .04036 .03848 .03674 .03510 .03358 .03215 .03081 31 .04969 .04727 .04501 .04291 .04094 .03911 .03739 .03579 .03428 .03287 32 .05272 .05019 .04783 .04563 .04357 .04165 .03984 .03816 .03657 .03509 33 .05595 .05331 .05085 .04854 .04639 .04437 .04248 .04070 .03904 .03748 34 .05936 .05661 .05403 .05162 .04936 .04725 .04527 .04341 .04166 .04001

35 .06297 .06010 .05741 .05489 .05253 .05032 .04824 .04629 .04445 .04272 36 .06679 .06380 .06100 .05837 .05590 .05358 .05140 .04935 .04742 .04561 37 .07083 .06771 .06479 .06204 .05947 .05704 .05476 .05261 .05059 .04868 38 .07511 .07186 .06881 .06595 .06326 .06072 .05834 .05609 .05397 .05196 39 .07961 .07623 .07306 .07007 .06726 .06462 .06212 .05977 .05754 .05544

40 .08434 .08083 .07753 .07442 .07149 .06873 .06612 .06366 .06133 .05913 41 .08932 .08568 .08225 .07901 .07596 .07308 .07035 .06778 .06534 .06304 42 .09455 .09077 .08720 .08384 .08066 .07766 .07481 .07213 .06958 .06717 43 .10007 .09615 .09245 .08895 .08564 .08251 .07955 .07674 .07408 .07156 44 .10586 .10180 .09796 .09433 .09089 .08763 .08454 .08162 .07884 .07621

45 .11195 .10774 .10376 .09999 .09642 .09303 .08982 .08677 .08387 .08112 46 .11835 .11400 .10987 .10596 .10225 .09873 .09539 .09222 .08920 .08633 47 .12505 .12055 .11629 .11224 .10839 .10474 .10126 .09796 .09482 .09182 48 .13209 .12745 .12303 .11884 .11485 .11106 .10746 .10402 .10075 .09764 49 .13948 .13469 .13013 .12579 .12167 .11774 .11400 .11043 .10703 .10379

50 .14727 .14233 .13762 .13314 .12887 .12481 .12093 .11723 .11370 .11033 51 .15546 .15037 .14551 .14089 .13648 .13228 .12826 .12443 .12077 .11726 52 .16407 .15884 .15384 .14907 .14452 .14018 .13603 .13206 .12826 .12463 53 .17312 .16774 .16260 .15769 .15300 .14852 .14423 .14012 .13620 .13243 54 .18259 .17707 .17179 .16674 .16191 .15729 .15286 .14862 .14456 .14067

55 .19247 .18680 .18139 .17620 .17123 .16648 .16192 .15755 .15335 .14933 56 .20270 .19690 .19135 .18602 .18092 .17603 .17134 .16684 .16251 .15836 57 .21329 .20736 .20167 .19622 .19099 .18596 .18114 .17650 .17205 .16777 58 .22422 .21816 .21235 .20677 .20140 .19625 .19130 .18653 .18195 .17754 59 .23553 .22935 .22341 .21770 .21221 .20693 .20185 .19696 .19225 .18772

60 .24725 .24095 .23489 .22906 .22345 .21805 .21285 .20783 .20300 .19834 61 .25937 .25296 .24679 .24084 .23511 .22959 .22427 .21914 .21419 .20941 62 .27185 .26534 .25906 .25300 .24716 .24153 .23609 .23084 .22577 .22088 63 .28469 .27808 .27169 .26553 .25959 .25384 .24830 .24294 .23776 .23275 64 .29789 .29119 .28471 .27845 .27240 .26656 .26091 .25544 .25016 .24504

May 18, 2009 957 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

68 .35552 .34855 .34179 .33523 .32887 .32270 .31671 .31089 .30524 .29976 69 .37115 .36414 .35734 .35073 .34432 .33809 .33204 .32616 .32045 .31489

70 .38719 .38016 .37332 .36668 .36023 .35396 .34786 .34193 .33616 .33054 71 .40366 .39662 .38977 .38311 .37663 .37032 .36419 .35821 .35240 .34674 72 .42053 .41350 .40665 .39998 .39349 .38716 .38100 .37500 .36916 .36346 73 .43774 .43073 .42389 .41723 .41074 .40441 .39824 .39222 .38636 .38063 74 .45519 .44821 .44140 .43476 .42829 .42197 .41580 .40979 .40391 .39818

75 .47280 .46587 .45910 .45250 .44605 .43975 .43360 .42759 .42173 .41599 76 .49051 .48364 .47693 .47037 .46396 .45770 .45158 .44560 .43975 .43403 77 .50830 .50150 .49486 .48836 .48201 .47580 .46972 .46377 .45795 .45225 78 .52613 .51942 .51286 .50644 .50015 .49400 .48797 .48208 .47630 .47064 79 .54396 .53736 .53089 .52456 .51835 .51227 .50632 .50048 .49476 .48915

80 .56174 .55525 .54888 .54265 .53653 .53054 .52466 .51890 .51325 .50770 81 .57941 .57305 .56681 .56068 .55467 .54878 .54299 .53731 .53174 .52627 82 .59696 .59073 .58461 .57861 .57272 .56693 .56125 .55566 .55018 .54480 83 .61430 .60822 .60224 .59637 .59061 .58494 .57937 .57389 .56851 .56322 84 .63142 .62549 .61966 .61393 .60830 .60276 .59731 .59196 .58669 .58150

85 .64825 .64249 .63682 .63124 .62575 .62035 .61503 .60980 .60465 .59958 86 .66477 .65918 .65367 .64825 .64291 .63765 .63248 .62738 .62236 .61741 87 .68092 .67550 .67016 .66490 .65972 .65462 .64959 .64463 .63975 .63493 88 .69669 .69145 .68628 .68119 .67618 .67123 .66635 .66154 .65680 .65212 89 .71201 .70696 .70198 .69706 .69221 .68742 .68270 .67805 .67345 .66892

90 .72688 .72201 .71721 .71246 .70779 .70317 .69861 .69411 .68966 .68528 91 .74126 .73658 .73196 .72739 .72289 .71844 .71404 .70970 .70541 .70117 92 .75513 .75063 .74620 .74181 .73748 .73320 .72897 .72479 .72066 .71657 93 .76844 .76414 .75988 .75568 .75152 .74741 .74334 .73932 .73535 .73142 94 .78123 .77711 .77303 .76901 .76502 .76108 .75718 .75332 .74951 .74573

95 .79348 .78954 .78565 .78179 .77798 .77421 .77047 .76677 .76312 .75950 96 .80513 .80137 .79765 .79397 .79032 .78671 .78314 .77960 .77610 .77263 97 .81621 .81262 .80908 .80556 .80208 .79864 .79522 .79184 .78849 .78517 98 .82674 .82333 .81995 .81660 .81328 .80999 .80673 .80351 .80031 .79713 99 .83677 .83352 .83030 .82711 .82395 .82082 .81771 .81463 .81158 .80855

100 .84616 .84307 .84001 .83697 .83396 .83097 .82801 .82507 .82216 .81927 101 .85514 .85221 .84930 .84641 .84355 .84070 .83788 .83509 .83231 .82956 102 .86348 .86069 .85792 .85517 .85245 .84974 .84706 .84439 .84175 .83912 103 .87182 .86918 .86655 .86395 .86136 .85880 .85625 .85372 .85121 .84872 104 .87950 .87699 .87450 .87203 .86957 .86713 .86471 .86231 .85992 .85755

105 .88706 .88468 .88232 .87998 .87765 .87534 .87304 .87076 .86849 .86624 106 .89664 .89444 .89225 .89008 .88792 .88577 .88364 .88152 .87941 .87731 107 .90756 .90557 .90358 .90160 .89964 .89768 .89574 .89380 .89188 .88997 108 .92565 .92401 .92238 .92075 .91914 .91753 .91592 .91433 .91274 .91116 109 .96211 .96125 .96041 .95956 .95872 .95788 .95704 .95620 .95537 .95455

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01132 .01110 .01089 .01071 .01053 .01037 .01022 .01008 .00995 .00983

2009–20 I.R.B. 958 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

1 .00520 .00497 .00476 .00457 .00439 .00423 .00407 .00393 .00379 .00367 2 .00521 .00496 .00474 .00454 .00435 .00417 .00401 .00385 .00371 .00358 3 .00539 .00513 .00490 .00468 .00447 .00429 .00411 .00395 .00380 .00366 4 .00567 .00540 .00515 .00492 .00470 .00450 .00432 .00414 .00398 .00383

5 .00603 .00574 .00547 .00523 .00500 .00478 .00459 .00440 .00423 .00407 6 .00646 .00615 .00587 .00560 .00536 .00513 .00492 .00472 .00453 .00436 7 .00693 .00660 .00630 .00602 .00576 .00551 .00529 .00508 .00488 .00469 8 .00747 .00712 .00680 .00650 .00622 .00596 .00572 .00549 .00528 .00509 9 .00808 .00771 .00737 .00705 .00675 .00648 .00622 .00598 .00576 .00555

10 .00877 .00838 .00801 .00767 .00736 .00707 .00679 .00654 .00630 .00608 11 .00954 .00912 .00873 .00838 .00804 .00773 .00744 .00717 .00692 .00668 12 .01038 .00994 .00953 .00915 .00880 .00847 .00816 .00788 .00761 .00735 13 .01127 .01081 .01038 .00998 .00960 .00925 .00893 .00862 .00833 .00806 14 .01217 .01168 .01122 .01080 .01040 .01003 .00969 .00937 .00906 .00878

15 .01305 .01253 .01205 .01160 .01118 .01079 .01042 .01008 .00976 .00946 16 .01387 .01333 .01282 .01234 .01190 .01149 .01110 .01074 .01040 .01009 17 .01467 .01409 .01356 .01306 .01259 .01216 .01175 .01137 .01101 .01067 18 .01544 .01484 .01427 .01374 .01325 .01279 .01236 .01195 .01157 .01122 19 .01621 .01557 .01497 .01442 .01390 .01341 .01295 .01253 .01213 .01175

20 .01702 .01634 .01571 .01512 .01457 .01406 .01357 .01312 .01270 .01230 21 .01784 .01713 .01646 .01584 .01526 .01471 .01420 .01372 .01327 .01285 22 .01870 .01794 .01724 .01658 .01596 .01539 .01485 .01434 .01386 .01342 23 .01961 .01881 .01807 .01737 .01672 .01611 .01554 .01500 .01449 .01402 24 .02062 .01977 .01899 .01825 .01756 .01691 .01630 .01573 .01520 .01469

25 .02175 .02085 .02002 .01924 .01851 .01782 .01718 .01657 .01600 .01547 26 .02301 .02207 .02119 .02036 .01958 .01886 .01817 .01753 .01692 .01635 27 .02443 .02343 .02250 .02162 .02080 .02003 .01930 .01862 .01798 .01737 28 .02600 .02495 .02396 .02303 .02216 .02134 .02057 .01985 .01916 .01852 29 .02771 .02660 .02555 .02457 .02365 .02278 .02197 .02120 .02047 .01979

30 .02956 .02838 .02728 .02624 .02526 .02434 .02348 .02266 .02189 .02116 31 .03155 .03031 .02914 .02804 .02701 .02604 .02512 .02425 .02344 .02266 32 .03370 .03239 .03115 .02999 .02890 .02787 .02690 .02598 .02511 .02429 33 .03601 .03463 .03333 .03210 .03095 .02985 .02883 .02785 .02693 .02606 34 .03847 .03701 .03564 .03434 .03312 .03197 .03088 .02985 .02887 .02795

35 .04109 .03956 .03811 .03675 .03546 .03424 .03308 .03199 .03096 .02998 36 .04390 .04228 .04076 .03932 .03795 .03667 .03545 .03429 .03320 .03216 37 .04688 .04518 .04358 .04206 .04062 .03926 .03798 .03676 .03560 .03450 38 .05007 .04829 .04660 .04500 .04349 .04205 .04069 .03940 .03818 .03701 39 .05346 .05158 .04981 .04812 .04653 .04502 .04358 .04222 .04092 .03969

40 .05705 .05508 .05321 .05144 .04976 .04817 .04666 .04522 .04385 .04255 41 .06086 .05879 .05683 .05497 .05320 .05152 .04993 .04841 .04697 .04559 42 .06488 .06271 .06066 .05870 .05684 .05508 .05340 .05180 .05028 .04882 43 .06917 .06690 .06474 .06269 .06074 .05888 .05711 .05543 .05382 .05229 44 .07370 .07132 .06906 .06691 .06486 .06291 .06105 .05928 .05759 .05598

45 .07850 .07602 .07365 .07139 .06924 .06719 .06524 .06338 .06160 .05990 46 .08360 .08100 .07852 .07616 .07390 .07176 .06970 .06775 .06587 .06409 47 .08897 .08626 .08367 .08120 .07884 .07659 .07443 .07238 .07041 .06853 48 .09466 .09183 .08912 .08654 .08407 .08172 .07946 .07730 .07524 .07326 49 .10069 .09774 .09492 .09222 .08964 .08717 .08481 .08255 .08038 .07831

50 .10711 .10403 .10109 .09827 .09558 .09300 .09053 .08816 .08589 .08371 51 .11392 .11072 .10765 .10472 .10191 .09921 .09663 .09415 .09178 .08950

May 18, 2009 959 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

52 .12116 .11783 .11464 .11159 .10866 .10585 .10315 .10057 .09808 .09569 53 .12883 .12538 .12206 .11889 .11584 .11291 .11010 .10740 .10481 .10231 54 .13694 .13336 .12992 .12662 .12345 .12041 .11748 .11467 .11196 .10936

55 .14547 .14176 .13820 .13478 .13149 .12832 .12528 .12235 .11953 .11682 56 .15437 .15054 .14685 .14330 .13989 .13661 .13345 .13040 .12747 .12464 57 .16365 .15969 .15588 .15221 .14868 .14527 .14199 .13883 .13578 .13284 58 .17330 .16921 .16528 .16149 .15783 .15431 .15091 .14763 .14447 .14141 59 .18335 .17914 .17508 .17117 .16739 .16375 .16023 .15684 .15356 .15039

60 .19385 .18952 .18534 .18131 .17741 .17365 .17001 .16650 .16311 .15982 61 .20480 .20035 .19605 .19189 .18788 .18400 .18025 .17662 .17311 .16971 62 .21615 .21158 .20717 .20290 .19877 .19477 .19090 .18716 .18354 .18003 63 .22791 .22323 .21870 .21431 .21007 .20596 .20198 .19812 .19439 .19077 64 .24009 .23530 .23066 .22616 .22181 .21758 .21349 .20953 .20568 .20195

65 .25271 .24781 .24306 .23846 .23400 .22967 .22547 .22139 .21744 .21360 66 .26600 .26100 .25615 .25145 .24688 .24245 .23814 .23396 .22990 .22596 67 .27992 .27483 .26989 .26509 .26043 .25590 .25150 .24722 .24306 .23901 68 .29443 .28926 .28423 .27934 .27459 .26997 .26548 .26110 .25685 .25271 69 .30950 .30424 .29914 .29417 .28934 .28463 .28005 .27559 .27125 .26703

70 .32508 .31976 .31459 .30955 .30464 .29986 .29520 .29067 .28625 .28194 71 .34122 .33585 .33062 .32552 .32054 .31570 .31097 .30637 .30187 .29749 72 .35790 .35249 .34721 .34205 .33703 .33213 .32734 .32268 .31812 .31367 73 .37505 .36960 .36428 .35909 .35403 .34908 .34425 .33953 .33492 .33042 74 .39258 .38711 .38177 .37655 .37145 .36647 .36160 .35684 .35219 .34764

75 .41039 .40491 .39956 .39432 .38921 .38420 .37931 .37452 .36983 .36525 76 .42843 .42296 .41760 .41236 .40724 .40222 .39731 .39250 .38779 .38318 77 .44668 .44122 .43588 .43065 .42552 .42050 .41559 .41077 .40605 .40143 78 .46510 .45967 .45435 .44914 .44403 .43902 .43411 .42930 .42458 .41995 79 .48365 .47826 .47298 .46780 .46271 .45773 .45284 .44804 .44333 .43871

80 .50226 .49693 .49169 .48655 .48150 .47655 .47169 .46692 .46224 .45763 81 .52090 .51562 .51044 .50536 .50036 .49546 .49064 .48590 .48125 .47668 82 .53951 .53431 .52920 .52418 .51924 .51439 .50963 .50494 .50033 .49580 83 .55802 .55291 .54788 .54294 .53808 .53329 .52859 .52396 .51941 .51493 84 .57640 .57139 .56645 .56159 .55681 .55210 .54747 .54291 .53843 .53401

85 .59459 .58968 .58484 .58008 .57539 .57077 .56623 .56175 .55733 .55298 86 .61254 .60774 .60302 .59836 .59377 .58925 .58479 .58040 .57607 .57180 87 .63019 .62551 .62090 .61635 .61187 .60745 .60309 .59880 .59456 .59038 88 .64751 .64296 .63847 .63405 .62968 .62537 .62112 .61693 .61279 .60871 89 .66444 .66003 .65567 .65137 .64712 .64293 .63880 .63471 .63068 .62670

90 .68094 .67667 .67244 .66827 .66415 .66009 .65607 .65210 .64818 .64431 91 .69699 .69285 .68877 .68473 .68074 .67680 .67291 .66906 .66526 .66150 92 .71254 .70855 .70460 .70071 .69685 .69304 .68928 .68555 .68187 .67823 93 .72753 .72369 .71989 .71613 .71242 .70874 .70510 .70150 .69794 .69442 94 .74200 .73830 .73464 .73103 .72745 .72390 .72040 .71693 .71350 .71010

95 .75591 .75236 .74885 .74538 .74194 .73853 .73516 .73182 .72851 .72524 96 .76920 .76580 .76243 .75909 .75579 .75252 .74928 .74607 .74289 .73974 97 .78188 .77863 .77540 .77220 .76904 .76590 .76279 .75971 .75665 .75363 98 .79399 .79088 .78779 .78473 .78170 .77869 .77571 .77276 .76983 .76693 99 .80555 .80257 .79962 .79670 .79380 .79092 .78807 .78525 .78244 .77966

100 .81641 .81357 .81075 .80796 .80518 .80243 .79971 .79700 .79432 .79165 101 .82683 .82412 .82144 .81877 .81612 .81350 .81089 .80831 .80574 .80320 102 .83652 .83394 .83137 .82882 .82630 .82379 .82130 .81883 .81637 .81394

2009–20 I.R.B. 960 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

103 .84624 .84379 .84135 .83892 .83652 .83413 .83176 .82941 .82707 .82475 104 .85519 .85285 .85053 .84822 .84593 .84365 .84139 .83915 .83692 .83470

105 .86400 .86178 .85957 .85737 .85519 .85302 .85087 .84873 .84660 .84449 106 .87523 .87316 .87110 .86905 .86702 .86500 .86299 .86099 .85900 .85703 107 .88806 .88617 .88429 .88242 .88055 .87870 .87686 .87502 .87320 .87139 108 .90958 .90802 .90646 .90490 .90336 .90182 .90028 .89876 .89724 .89573 109 .95372 .95290 .95208 .95126 .95045 .94964 .94883 .94803 .94723 .94643

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

0 .00972 .00961 .00951 .00941 .00932 .00924 .00916 .00908 .00901 .00894 1 .00355 .00345 .00334 .00325 .00316 .00307 .00299 .00292 .00285 .00278 2 .00346 .00334 .00323 .00313 .00303 .00294 .00286 .00278 .00270 .00263 3 .00353 .00340 .00329 .00318 .00307 .00298 .00289 .00280 .00272 .00264 4 .00369 .00356 .00343 .00332 .00321 .00310 .00300 .00291 .00283 .00274

5 .00392 .00377 .00364 .00352 .00340 .00329 .00318 .00308 .00299 .00290 6 .00420 .00405 .00391 .00377 .00365 .00353 .00342 .00331 .00321 .00311 7 .00452 .00436 .00421 .00406 .00393 .00380 .00368 .00357 .00346 .00336 8 .00490 .00473 .00457 .00441 .00427 .00413 .00400 .00388 .00376 .00365 9 .00535 .00517 .00499 .00483 .00467 .00453 .00439 .00426 .00413 .00402

10 .00587 .00567 .00548 .00531 .00514 .00499 .00484 .00470 .00456 .00444 11 .00645 .00624 .00605 .00586 .00568 .00551 .00536 .00521 .00506 .00493 12 .00711 .00689 .00668 .00648 .00629 .00611 .00595 .00579 .00563 .00549 13 .00781 .00757 .00735 .00714 .00694 .00675 .00657 .00640 .00624 .00609 14 .00851 .00826 .00802 .00780 .00759 .00739 .00720 .00702 .00684 .00668

15 .00918 .00891 .00866 .00842 .00820 .00799 .00779 .00759 .00741 .00724 16 .00979 .00950 .00924 .00899 .00875 .00853 .00832 .00811 .00792 .00774 17 .01035 .01006 .00978 .00951 .00926 .00902 .00880 .00859 .00838 .00819 18 .01088 .01057 .01027 .00999 .00973 .00948 .00924 .00901 .00880 .00860 19 .01139 .01106 .01075 .01045 .01017 .00990 .00965 .00942 .00919 .00898

20 .01192 .01157 .01124 .01092 .01063 .01035 .01008 .00983 .00959 .00936 21 .01245 .01208 .01173 .01139 .01108 .01078 .01050 .01023 .00998 .00974 22 .01300 .01260 .01222 .01187 .01154 .01122 .01092 .01064 .01037 .01011 23 .01357 .01315 .01275 .01238 .01202 .01168 .01137 .01106 .01078 .01051 24 .01422 .01377 .01334 .01294 .01257 .01221 .01187 .01155 .01124 .01095

25 .01496 .01448 .01403 .01361 .01320 .01282 .01246 .01212 .01180 .01149 26 .01582 .01531 .01483 .01438 .01395 .01354 .01316 .01279 .01244 .01211 27 .01680 .01626 .01575 .01527 .01481 .01437 .01396 .01357 .01320 .01285 28 .01791 .01734 .01679 .01628 .01579 .01533 .01489 .01447 .01408 .01370 29 .01914 .01853 .01795 .01740 .01688 .01639 .01592 .01548 .01505 .01465

30 .02048 .01982 .01921 .01862 .01807 .01754 .01704 .01657 .01612 .01569 31 .02193 .02124 .02058 .01996 .01937 .01881 .01828 .01777 .01729 .01683 32 .02351 .02278 .02208 .02142 .02079 .02019 .01962 .01908 .01857 .01808 33 .02523 .02445 .02371 .02300 .02234 .02170 .02109 .02052 .01997 .01944 34 .02707 .02624 .02545 .02470 .02399 .02331 .02267 .02205 .02146 .02091

35 .02905 .02817 .02733 .02653 .02577 .02505 .02436 .02371 .02308 .02249

May 18, 2009 961 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

36 .03117 .03024 .02935 .02850 .02769 .02693 .02619 .02550 .02483 .02419 37 .03345 .03246 .03151 .03061 .02976 .02894 .02816 .02742 .02671 .02603 38 .03590 .03485 .03385 .03289 .03198 .03112 .03029 .02950 .02874 .02802 39 .03852 .03740 .03634 .03533 .03436 .03344 .03256 .03172 .03092 .03015

40 .04131 .04013 .03900 .03793 .03690 .03593 .03499 .03410 .03324 .03242 41 .04428 .04303 .04184 .04070 .03962 .03858 .03759 .03664 .03573 .03486 42 .04744 .04612 .04486 .04366 .04250 .04140 .04035 .03934 .03838 .03745 43 .05083 .04943 .04810 .04683 .04561 .04444 .04333 .04226 .04123 .04025 44 .05443 .05296 .05155 .05021 .04892 .04768 .04650 .04537 .04428 .04324

45 .05827 .05672 .05523 .05381 .05245 .05114 .04989 .04869 .04754 .04643 46 .06237 .06074 .05917 .05767 .05623 .05485 .05352 .05225 .05103 .04986 47 .06673 .06500 .06335 .06177 .06025 .05879 .05739 .05605 .05475 .05351 48 .07137 .06955 .06781 .06614 .06454 .06300 .06152 .06010 .05874 .05742 49 .07632 .07441 .07258 .07082 .06913 .06750 .06595 .06444 .06300 .06161

50 .08162 .07962 .07769 .07584 .07407 .07236 .07071 .06913 .06760 .06614 51 .08731 .08520 .08318 .08124 .07937 .07757 .07583 .07416 .07256 .07101 52 .09340 .09119 .08907 .08703 .08507 .08317 .08135 .07959 .07790 .07627 53 .09991 .09760 .09538 .09324 .09118 .08919 .08728 .08543 .08365 .08193 54 .10685 .10443 .10211 .09987 .09771 .09562 .09361 .09167 .08980 .08799

55 .11420 .11168 .10925 .10690 .10464 .10246 .10035 .09832 .09635 .09445 56 .12191 .11928 .11675 .11430 .11193 .10965 .10745 .10531 .10325 .10126 57 .13001 .12727 .12462 .12207 .11960 .11721 .11491 .11268 .11052 .10843 58 .13846 .13561 .13286 .13020 .12762 .12513 .12273 .12040 .11814 .11595 59 .14732 .14436 .14150 .13873 .13605 .13346 .13095 .12851 .12616 .12388

60 .15665 .15358 .15060 .14772 .14494 .14224 .13962 .13709 .13463 .13225 61 .16642 .16324 .16016 .15717 .15428 .15147 .14875 .14611 .14355 .14107 62 .17663 .17333 .17014 .16704 .16404 .16113 .15830 .15556 .15290 .15031 63 .18726 .18385 .18055 .17734 .17423 .17121 .16828 .16544 .16267 .15999 64 .19833 .19481 .19140 .18809 .18487 .18175 .17871 .17576 .17289 .17010

65 .20987 .20624 .20273 .19931 .19598 .19275 .18961 .18656 .18358 .18069 66 .22213 .21840 .21478 .21125 .20783 .20449 .20125 .19809 .19501 .19202 67 .23508 .23125 .22753 .22390 .22037 .21694 .21360 .21034 .20716 .20407 68 .24868 .24476 .24094 .23722 .23359 .23006 .22662 .22327 .22000 .21681 69 .26291 .25889 .25498 .25117 .24745 .24383 .24030 .23685 .23349 .23020

70 .27773 .27364 .26964 .26574 .26194 .25823 .25461 .25107 .24762 .24425 71 .29321 .28904 .28496 .28099 .27710 .27331 .26961 .26599 .26246 .25900 72 .30933 .30508 .30094 .29689 .29294 .28907 .28530 .28160 .27799 .27446 73 .32602 .32171 .31751 .31340 .30938 .30545 .30160 .29784 .29416 .29056 74 .34319 .33884 .33458 .33042 .32634 .32236 .31845 .31463 .31089 .30723

75 .36076 .35637 .35207 .34786 .34374 .33970 .33575 .33188 .32808 .32437 76 .37867 .37425 .36991 .36567 .36151 .35744 .35344 .34953 .34569 .34192 77 .39690 .39245 .38810 .38383 .37964 .37554 .37151 .36756 .36369 .35989 78 .41541 .41096 .40659 .40231 .39811 .39398 .38993 .38596 .38206 .37823 79 .43418 .42973 .42536 .42107 .41686 .41272 .40866 .40467 .40075 .39691

80 .45311 .44868 .44432 .44003 .43582 .43169 .42763 .42363 .41971 .41585 81 .47219 .46777 .46343 .45916 .45497 .45084 .44679 .44280 .43888 .43502 82 .49135 .48696 .48265 .47841 .47424 .47014 .46610 .46213 .45822 .45437 83 .51052 .50618 .50191 .49771 .49357 .48950 .48549 .48154 .47766 .47383 84 .52966 .52537 .52115 .51700 .51291 .50887 .50490 .50099 .49714 .49334

85 .54870 .54448 .54032 .53622 .53218 .52820 .52428 .52041 .51660 .51284 86 .56759 .56344 .55935 .55532 .55135 .54742 .54356 .53974 .53598 .53227

2009–20 I.R.B. 962 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

87 .58626 .58219 .57818 .57422 .57031 .56646 .56266 .55891 .55521 .55155 88 .60468 .60070 .59677 .59290 .58907 .58529 .58157 .57788 .57425 .57066 89 .62277 .61888 .61505 .61126 .60753 .60383 .60018 .59658 .59302 .58950

90 .64048 .63670 .63296 .62927 .62563 .62202 .61846 .61494 .61146 .60803 91 .65778 .65411 .65048 .64689 .64334 .63983 .63636 .63293 .62954 .62619 92 .67462 .67106 .66754 .66406 .66061 .65720 .65383 .65050 .64720 .64393 93 .69094 .68749 .68408 .68071 .67737 .67406 .67079 .66756 .66435 .66118 94 .70673 .70340 .70011 .69685 .69362 .69042 .68725 .68412 .68102 .67794

95 .72199 .71878 .71560 .71246 .70934 .70625 .70319 .70016 .69716 .69419 96 .73662 .73353 .73047 .72743 .72443 .72145 .71850 .71557 .71268 .70981 97 .75063 .74766 .74471 .74180 .73890 .73604 .73319 .73038 .72758 .72482 98 .76405 .76120 .75837 .75557 .75279 .75003 .74730 .74459 .74190 .73923 99 .77690 .77417 .77146 .76877 .76610 .76345 .76083 .75822 .75564 .75308

100 .78901 .78639 .78379 .78121 .77866 .77612 .77360 .77110 .76862 .76616 101 .80067 .79816 .79568 .79321 .79076 .78832 .78591 .78351 .78114 .77877 102 .81152 .80912 .80674 .80438 .80203 .79970 .79738 .79508 .79280 .79054 103 .82245 .82016 .81789 .81563 .81339 .81116 .80895 .80676 .80458 .80241 104 .83250 .83031 .82814 .82599 .82384 .82171 .81960 .81750 .81541 .81334

105 .84239 .84030 .83823 .83617 .83412 .83209 .83006 .82806 .82606 .82407 106 .85507 .85311 .85117 .84924 .84733 .84542 .84352 .84164 .83976 .83790 107 .86958 .86779 .86600 .86422 .86246 .86070 .85895 .85721 .85548 .85376 108 .89422 .89272 .89123 .88974 .88826 .88679 .88533 .88386 .88241 .88096 109 .94563 .94484 .94405 .94326 .94248 .94170 .94092 .94014 .93937 .93860

if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a pooled income fund for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of the remainder interest under this section is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(5) or (f)(6) of this section, at the option of

(f) Effective/applicability date . This section applies on or after May 1, 2009.

(g) Expiration date . This section expires on or before May 1, 2012.

Par. 6. The undesignated center heading immediately preceding §1.642(c)–6A is revised to read as follows:

Pooled Income Fund Actuarial Tables

Applicable Before May 1, 2009

Par. 7. Section 1.642(c)–6A is amended by:

Revising the section heading.
Amending newly-designated paragraph (f) as follows:

a. Paragraph (f) heading is revised. b. Paragraphs (f)(1), (f)(2), (f)(3), (f)(4), and (f)(5) are revised.

c. The introductory text in paragraph (f)(6) and the heading preceding Table S is are revised.

d. Paragraph (f)(7) is added. The revisions and addition read as follows:

§1.642(c)–6A Valuation of charitable remainder interests for which the valuation date is before May 1, 2009.

- - - (f) Present value of the remainder inter- est in the case of transfers to pooled in- come funds for which the valuation date is after April 30, 1999, and before May 1, 2009 —(1) In general . In the case of transfers to pooled income funds for which the valuation date is after April 30, 1999, and before May 1, 2009, the present value of a remainder interest is determined under this section. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). The present value of a remainder interest that is dependent on the termination of the life of one individual is computed by the use of Table S in paragraph (f)(6) of this section. For purposes of the computations under this section, the age of an individual is the age at the individual’s nearest birthday.

(2) Transitional rules for valuation of transfers to pooled income funds . (i) For purposes of sections 2055, 2106, or 2624,

May 18, 2009 963 2009–20 I.R.B.

(as described in this section) is the net fair market value (as of the appropriate valuation date) of the property placed in trust less the present value of the annuity. For purposes of this section, valuation date means, in general, the date on which the property is transferred to the trust by the donor regardless of when the trust is created. In the case of transfers to a charitable remainder annuity trust for which the valuation date is after April 30, 1999, if an election is made under section 7520 and §1.7520–2(b) to compute the present value of the charitable interest by use of the interest rate component for either of the 2 months preceding the month in which the transfer is made, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. For purposes of section 2055 or 2106, the valuation date is the date of death unless the alternate valuation date is elected in accordance with section 2032 in which event, and within the limitations set forth in section 2032 and the regulations thereunder, the valuation date is the alternate valuation date. If the decedent’s estate elects the alternate valuation date under section 2032 and also elects, under section 7520 and §1.7520–2(b), to use the interest rate component for one of the 2 months preceding the alternate valuation date, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. The present value of an annuity is computed under §20.2031–7T(d) for transfers for which the valuation date is on or after May 1, 2009, or under §20.2031–7A(a) through (f), whichever is applicable, for transfers for which the valuation date is before May 1, 2009. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances).

- - - (e) Effective/applicability date . Paragraph (c)(1) applies after April 30, 1989.

Par. 9. Section 1.664–4 is amended as follows:

Paragraph (a)(1) is revised.
Paragraph (d) is removed.
The heading for paragraph (e) is redesignated as the heading for §1.664–4A(f).
Paragraphs (e)(1), (e)(2), (e)(5), and (e)(7) are redesignated as

the donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (f)(2)(i) and (f)(2)(ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(5) or (f)(6) of this section, the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) Present value of a remainder inter- est . The present value of a remainder interest in property transferred to a pooled income fund is computed on the basis of

(i) Life contingencies determined from the values of lx that are set forth in Table 90CM in §20.2031–7A(f)(4); and (ii) Discount at a rate of interest, compounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. The provisions of §1.642(c)–6(c) apply for determining the yearly rate of return. However, where the taxable year is less than 12 months, the provisions of §1.642(c)–6T(e)(3)(ii) apply for the determining the yearly rate of return.

(4) Pooled income funds in existence less than 3 taxable years . The provisions of §1.642(c)–6T(e)(4) apply for determining the highest yearly rate of return when the pooled income fund has been in existence less than three taxable years.

(5) Computation of value of remainder interest . The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (f)(6) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based. Table S in paragraph (f)(6) of this section includes factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained

in Table S in paragraph (f)(6) of this section are contained in Table S in Internal Revenue Service Publication 1457, “Actu- arial Values, Book Aleph,” (7–99). Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office. However, pertinent factors in this publication may be obtained by a written request to: CC:PA:LPD:PR (IRS Publication 1457), Room 5205, Internal Revenue Service, P.O.Box 7604, Ben Franklin Station, Washington, DC 20044. For other situations, see §1.642(c)–6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor. For an example of a computation of the present value of a remainder interest requiring a linear interpolation adjustment, see §1.642(c)–6T(e)(5).

(6) Actuarial tables . In the case of transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, the present value of a remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined by use of the following tables:

TABLE S.—BASED ON LIFE

TABLE 90CM SINGLE LIFE

REMAINDER FACTORS

[Applicable After April 30, 1999,

and Before May 1, 2009]

- - - (7) Effective/applicability dates . Paragraphs (f)(1) through (f)(6) apply after April 30, 1999, and before May 1, 2009.

Par. 8. Section 1.664–2 is amended by revising paragraph (c) and adding paragraph (e) to read as follows:

§1.664–2 Charitable remainder annuity trust .

- - - (c) Calculation of the fair market value of the remainder interest of a charitable remainder annuity trust . For purposes of sections 170, 2055, 2106, and 2522, the fair market value of the remainder interest of a charitable remainder annuity trust

2009–20 I.R.B. 964 May 18, 2009

in a charitable remainder unitrust (temporary) .

(a) [Reserved]. For further guidance, see §1.664–4(a).

(1) Life contingencies determined as to each life involved, from the values of lx set forth in Table 2000CM contained in §20.2031–7T(d)(7) in the case of transfers for which the valuation date is on or after May 1, 2009; or from Table 90CM contained in §20.2031–7A(f)(4) in the case of transfer for which the valuation date is after April 30, 1999, and before May 1, 2009. See §20.2031–7A(a) through (e), whichever is applicable, for transfers for which the valuation date is before May 1, 1999; (a)(2) through (c) [Reserved]. For further guidance, see §1.664–4(a)(2) through (c).

(d) Valuation . The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is on or after May 1, 2009, is its present value determined under paragraph (e) of this section. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is before May 1, 2009, is its present value determined under the following sections:

§1.664–4A(f)(1), (f)(2), (f)(5) and (f)(6), respectively.

New paragraphs (d), (e)(1), (e)(2), and (e)(5) are added.
The heading and introductory text of paragraph (e)(6), preceding Table D, is revised.
New paragraph (e)(7) is added.
Paragraph (f) is revised. The additions and revision read as follows:

§1.664–4 Calculation of the fair market value of the remainder interest in a charitable remainder unitrust .

(a) - * (1) [Reserved]. For further guidance, see §1.664–4T(a)(1).

- - - (d) through (e)(2) [Reserved]. For further guidance, see §1.664–4T(d) through (e)(2).
- - - (5) [Reserved]. For further guidance, see §1.664–4T(e)(5).

(6) Actuarial Table D and F (4.2 through 14.0) for transfers for which the valuation date is after April 30, 1989 . For transfers for which the valuation date is after April 30, 1989, the present value of a charitable remainder unitrust interest

that is dependent upon a term of years is determined by using the section 7520 rate and the tables in this paragraph (e)(6). For transfers for which the valuation date is on or after May 1, 2009, where the present value of a charitable remainder unitrust interest is dependent on the termination of a life interest, see §1.664–4T(e)(5). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actu- arial Valuations Version 3B” (2009). This publication will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov .

- - - (7) [Reserved]. For further guidance, see §1.664–4T(e)(7).

(f) Effective/applicability dates . This section applies after April 30, 1999, and before May 1, 2009.

Par. 10. Section 1.664–4T is added to read as follows:

§1.664–4T Calculation of the fair market value of the remainder interest

Valuation Dates

After Before

Applicable Regulations

01–01–52 1.664–4A(a) 12–31–51 01–01–71 1.664–4A(b) 12–31–70 12–01–83 1.664–4A(c) 11–30–83 05–01–89 1.664–4A(d) 04–30–89 05–01–99 1.664–4A(e) 04–30–99 05–01–09 1.664–4A(f)

decedent died within 90 days of the date that the decedent first regained competency on or after May 1, 2009, the present value of a remainder interest under this section is determined as if the valuation date with respect to the decedent’s gross estate is either before or after May 1, 2009, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a charitable remainder unitrust for which the valuation date is on or after May 1, 2009, and before July 1, 2009, the present value of a remainder interest

(e) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is on or after May 1, 2009 —(1) In general . Except as otherwise provided in paragraph (e)(2) of this section, in the case of transfers for which the valuation date is on or after May 1, 2009, the present value of a remainder interest is determined under paragraphs (e)(3) through (e)(7) of this section, provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date

under §1.664–3(a)(1)(v) if the taxable year of the trust were to end on such date. See, however, §1.7520–3(b) (relating to exceptions to the use of the prescribed tables under certain circumstances).

(2) Transitional rules for valuation of charitable remainder unitrusts . (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 2009, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died on or after May 1, 2009, without having regained competency to dispose of the decedent’s property, or the

May 18, 2009 965 2009–20 I.R.B.

based on one or more measuring lives is determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(7) of this section or §1.664–4A(f)(6), at the option of the donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (e)(2)(i) and (e)(2)(ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(7) of this section or §1.664–4A(f)(6), the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includi

ble in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) and (4) [Reserved]. For further guidance, see §1.664–4(e)(3) and (e)(4).

(5) Period is the life of one indi- vidual . (i) If the period described in §1.664–3(a)(5) is the life of one individual, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is on or after May 1, 2009, is the factor in Table U(1) in paragraph (e)(7) of this section under the appropriate adjusted payout. For purposes of the computations described in this paragraph (e)(5), the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the

Factor at 7.6 percent at age 45 . . . . . . . . . . . . . . . . . . . . . . . .11141 Factor at 7.8 percent at age 45 . . . . . . . . . . . . . . . . . . . . . . . .10653 Difference . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .00488

Interpolation adjustment:

7.627% - 7.6% = x 0.2% .00488

x = .00066

Factor at 7.6 percent at age 45 . . . . . . . . . . . . . . . . . . . . . . . .11141 Less: Interpolation adjustment . . . . . . . . . . . . . . . . . . . . . . .00066 Interpolated Factor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11075

Present value of remainder interest:

($100,000 X .11075) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $11,075.00

net fair market value (as of the valuation date as determined in §1.664–4(e)(4)) of the property placed in trust by the factor determined under this paragraph (e)(5). If the adjusted payout rate is between 4.2 and 14 percent, see paragraph (e)(7) of this section. If the adjusted payout rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b).

(ii) The application of paragraph (e)(5)(i) of this section may be illustrated by the following example:

Example . A, who is 44 years and 11 months old, transfers $100,000 to a charitable remainder unitrust on January 1st. The trust instrument requires that the trust pay to A semiannually (on June 30 and December 31) 8 percent of the fair market value of the trust assets as of January 1st during A’s life. The section 7520 rate for January is 6.6 percent. Under Table F(6.6) in §1.664–4(e)(6), the appropriate adjustment factor is .953317 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 7.627% (8% X .953317). Based on the remainder factors in Table U(1) in this section, the present value of the remainder interest is $11,075.00, computed as follows:

ing tables are contained in Internal Revenue Service Publication 1458, “Actuarial Valuations Version 3B” (2009). This publication will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov .

(6) [Reserved]. For further guidance, see §1.664–4(e)(6).

(7) Actuarial Table U(1) for transfers for which the valuation date is on or after May 1, 2009. For transfers for which the valuation date is on or after May 1, 2009, the present value of a charitable remainder unitrust interest that is dependent on

the termination of a life interest is determined by using the section 7520 rate, Table U(1) in this paragraph (e)(7) and Table F(4.2) through (14.0) in §1.664–4(e)(6). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the follow

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

0 .05527 .04953 .04455 .04023 .03648 .03321 .03037 .02789 .02573 .02383 1 .05095 .04501 .03986 .03538 .03148 .02809 .02513 .02255 .02029 .01831 2 .05269 .04659 .04128 .03666 .03264 .02913 .02606 .02338 .02103 .01896

2009–20 I.R.B. 966 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

3 .05468 .04841 .04295 .03818 .03403 .03040 .02722 .02443 .02199 .01984 4 .05684 .05039 .04477 .03986 .03557 .03181 .02852 .02563 .02309 .02085

5 .05912 .05251 .04672 .04166 .03723 .03335 .02993 .02694 .02429 .02197 6 .06154 .05475 .04880 .04359 .03901 .03500 .03146 .02835 .02561 .02319 7 .06407 .05709 .05097 .04561 .04089 .03673 .03308 .02985 .02700 .02448 8 .06672 .05956 .05328 .04775 .04288 .03859 .03481 .03146 .02850 .02588 9 .06951 .06217 .05571 .05002 .04500 .04057 .03665 .03319 .03012 .02739

10 .07244 .06491 .05827 .05241 .04724 .04266 .03861 .03503 .03184 .02901 11 .07550 .06778 .06096 .05494 .04961 .04489 .04070 .03698 .03368 .03074 12 .07869 .07078 .06378 .05759 .05210 .04723 .04290 .03906 .03563 .03258 13 .08199 .07389 .06670 .06034 .05468 .04966 .04519 .04121 .03767 .03450 14 .08536 .07706 .06969 .06315 .05733 .05215 .04754 .04342 .03975 .03646

15 .08877 .08027 .07271 .06599 .06000 .05467 .04990 .04565 .04184 .03844 16 .09221 .08351 .07576 .06885 .06269 .05719 .05228 .04788 .04394 .04041 17 .09570 .08679 .07885 .07176 .06542 .05975 .05468 .05014 .04606 .04240 18 .09925 .09014 .08199 .07471 .06820 .06236 .05712 .05243 .04821 .04442 19 .10289 .09356 .08522 .07774 .07104 .06503 .05963 .05478 .05041 .04648

20 .10665 .09711 .08856 .08089 .07400 .06781 .06224 .05723 .05272 .04864 21 .11052 .10077 .09201 .08413 .07706 .07068 .06495 .05977 .05510 .05088 22 .11452 .10455 .09558 .08750 .08023 .07367 .06776 .06241 .05759 .05322 23 .11867 .10848 .09929 .09101 .08354 .07680 .07070 .06519 .06019 .05567 24 .12300 .11259 .10319 .09470 .08703 .08009 .07381 .06812 .06297 .05829

25 .12755 .11691 .10730 .09860 .09073 .08359 .07713 .07126 .06593 .06109 26 .13232 .12146 .11163 .10272 .09464 .08731 .08065 .07460 .06910 .06409 27 .13732 .12624 .11619 .10706 .09878 .09125 .08440 .07816 .07248 .06731 28 .14255 .13125 .12098 .11164 .10315 .09542 .08837 .08195 .07609 .07074 29 .14799 .13647 .12598 .11644 .10773 .09980 .09256 .08594 .07990 .07438

30 .15365 .14191 .13120 .12144 .11252 .10438 .09694 .09014 .08391 .07821 31 .15952 .14756 .13664 .12666 .11754 .10919 .10155 .09455 .08813 .08225 32 .16561 .15343 .14230 .13210 .12277 .11422 .10637 .09918 .09257 .08650 33 .17193 .15954 .14819 .13778 .12824 .11948 .11143 .10403 .09724 .09098 34 .17845 .16585 .15429 .14367 .13391 .12495 .11670 .10910 .10211 .09566

35 .18520 .17239 .16062 .14979 .13982 .13065 .12219 .11440 .10721 .10057 36 .19218 .17916 .16718 .15614 .14597 .13659 .12793 .11993 .11254 .10571 37 .19938 .18617 .17398 .16274 .15236 .14276 .13390 .12570 .11812 .11110 38 .20683 .19342 .18103 .16958 .15900 .14920 .14013 .13173 .12395 .11673 39 .21450 .20090 .18832 .17667 .16588 .15588 .14661 .13801 .13003 .12261

40 .22241 .20862 .19585 .18400 .17301 .16281 .15334 .14454 .13636 .12875 41 .23055 .21659 .20362 .19158 .18040 .17000 .16033 .15133 .14295 .13514 42 .23892 .22479 .21164 .19942 .18804 .17744 .16757 .15838 .14980 .14180 43 .24756 .23326 .21994 .20753 .19596 .18517 .17511 .16572 .15695 .14875 44 .25644 .24198 .22849 .21590 .20415 .19318 .18293 .17334 .16438 .15599

45 .26557 .25096 .23731 .22455 .21263 .20147 .19103 .18125 .17210 .16352 46 .27496 .26021 .24641 .23349 .22139 .21006 .19943 .18947 .18013 .17136 47 .28460 .26972 .25578 .24270 .23044 .21893 .20813 .19799 .18846 .17951 48 .29451 .27950 .26542 .25220 .23978 .22811 .21714 .20682 .19712 .18798 49 .30468 .28957 .27536 .26201 .24944 .23761 .22648 .21599 .20611 .19679

50 .31515 .29994 .28562 .27214 .25943 .24746 .23617 .22552 .21547 .20598 51 .32591 .31062 .29620 .28260 .26976 .25765 .24621 .23541 .22520 .21554 52 .33697 .32161 .30710 .29340 .28045 .26821 .25663 .24568 .23531 .22550 53 .34832 .33291 .31833 .30453 .29148 .27912 .26741 .25632 .24582 .23585

May 18, 2009 967 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

54 .35995 .34449 .32985 .31598 .30283 .29037 .27855 .26733 .25669 .24658

55 .37183 .35635 .34166 .32773 .31450 .30194 .29001 .27868 .26791 .25768 56 .38390 .36841 .35370 .33971 .32642 .31378 .30175 .29032 .27943 .26907 57 .39618 .38069 .36596 .35194 .33859 .32588 .31377 .30224 .29125 .28077 58 .40862 .39316 .37842 .36438 .35099 .33822 .32605 .31443 .30334 .29276 59 .42126 .40583 .39110 .37705 .36364 .35083 .33859 .32691 .31574 .30506

60 .43410 .41873 .40403 .38999 .37656 .36372 .35145 .33970 .32846 .31770 61 .44714 .43183 .41718 .40316 .38974 .37689 .36458 .35279 .34149 .33067 62 .46033 .44510 .43052 .41653 .40313 .39028 .37796 .36614 .35480 .34391 63 .47366 .45853 .44402 .43010 .41673 .40390 .39157 .37974 .36836 .35744 64 .48712 .47212 .45770 .44385 .43053 .41773 .40542 .39358 .38219 .37123

65 .50073 .48586 .47156 .45779 .44454 .43179 .41951 .40768 .39629 .38531 66 .51461 .49990 .48573 .47207 .45891 .44623 .43400 .42220 .41083 .39985 67 .52872 .51419 .50018 .48665 .47360 .46100 .44884 .43710 .42576 .41481 68 .54302 .52869 .51484 .50147 .48854 .47605 .46398 .45231 .44103 .43011 69 .55744 .54333 .52968 .51648 .50371 .49134 .47938 .46780 .45659 .44573

70 .57198 .55810 .54467 .53165 .51905 .50683 .49500 .48352 .47241 .46163 71 .58662 .57300 .55980 .54700 .53458 .52253 .51084 .49950 .48849 .47781 72 .60134 .58800 .57505 .56247 .55026 .53840 .52688 .51569 .50481 .49425 73 .61608 .60303 .59035 .57803 .56604 .55439 .54305 .53203 .52131 .51087 74 .63077 .61804 .60565 .59358 .58184 .57041 .55928 .54844 .53789 .52761

75 .64536 .63295 .62085 .60907 .59759 .58639 .57548 .56485 .55447 .54436 76 .65980 .64772 .63594 .62445 .61323 .60229 .59162 .58120 .57102 .56110 77 .67408 .66234 .65089 .63970 .62877 .61809 .60766 .59747 .58751 .57779 78 .68817 .67679 .66567 .65479 .64416 .63376 .62359 .61364 .60392 .59440 79 .70205 .69104 .68026 .66971 .65938 .64927 .63937 .62968 .62019 .61090

80 .71569 .70504 .69461 .68439 .67438 .66457 .65495 .64553 .63629 .62724 81 .72905 .71878 .70871 .69883 .68914 .67963 .67031 .66116 .65219 .64339 82 .74213 .73224 .72252 .71299 .70363 .69444 .68541 .67655 .66785 .65930 83 .75489 .74538 .73603 .72684 .71781 .70894 .70022 .69165 .68323 .67495 84 .76731 .75818 .74919 .74036 .73167 .72312 .71471 .70644 .69830 .69029

85 .77937 .77062 .76200 .75352 .74516 .73694 .72884 .72087 .71302 .70529 86 .79106 .78268 .77443 .76629 .75828 .75038 .74260 .73493 .72738 .71993 87 .80235 .79434 .78645 .77866 .77098 .76341 .75595 .74858 .74132 .73416 88 .81324 .80560 .79806 .79062 .78328 .77603 .76888 .76182 .75486 .74798 89 .82371 .81643 .80924 .80214 .79513 .78821 .78137 .77461 .76794 .76134

90 .83375 .82682 .81998 .81321 .80653 .79992 .79339 .78693 .78055 .77424 91 .84336 .83678 .83027 .82383 .81747 .81117 .80494 .79878 .79268 .78665 92 .85253 .84629 .84011 .83399 .82794 .82194 .81601 .81014 .80433 .79857 93 .86126 .85534 .84948 .84367 .83792 .83222 .82658 .82099 .81545 .80997 94 .86956 .86395 .85840 .85289 .84743 .84202 .83666 .83134 .82608 .82086

95 .87744 .87213 .86687 .86166 .85648 .85135 .84626 .84122 .83621 .83125 96 .88487 .87985 .87488 .86994 .86504 .86017 .85535 .85056 .84581 .84109 97 .89188 .88714 .88244 .87776 .87312 .86852 .86395 .85941 .85490 .85042 98 .89850 .89402 .88958 .88516 .88077 .87641 .87208 .86778 .86351 .85927 99 .90475 .90053 .89632 .89215 .88800 .88388 .87978 .87571 .87167 .86765

100 .91057 .90658 .90261 .89867 .89475 .89085 .88697 .88312 .87929 .87548 101 .91610 .91234 .90860 .90487 .90117 .89749 .89382 .89018 .88655 .88295 102 .92122 .91767 .91413 .91061 .90711 .90363 .90017 .89672 .89328 .88987 103 .92630 .92296 .91963 .91632 .91303 .90975 .90648 .90323 .89999 .89677 104 .93097 .92783 .92470 .92158 .91847 .91537 .91229 .90922 .90616 .90312

2009–20 I.R.B. 968 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

105 .93558 .93263 .92969 .92676 .92383 .92092 .91802 .91513 .91225 .90938 106 .94135 .93864 .93594 .93325 .93057 .92789 .92522 .92256 .91991 .91726 107 .94789 .94546 .94304 .94062 .93821 .93580 .93340 .93101 .92861 .92623 108 .95844 .95648 .95453 .95258 .95063 .94868 .94673 .94478 .94284 .94090 109 .97900 .97800 .97700 .97600 .97500 .97400 .97300 .97200 .97100 .97000

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

0 .02217 .02071 .01942 .01829 .01729 .01640 .01561 .01491 .01429 .01373 1 .01657 .01504 .01369 .01250 .01145 .01053 .00970 .00897 .00831 .00773 2 .01715 .01555 .01415 .01290 .01180 .01082 .00996 .00918 .00850 .00788 3 .01795 .01628 .01481 .01350 .01235 .01132 .01041 .00960 .00887 .00822 4 .01888 .01714 .01560 .01423 .01302 .01194 .01098 .01013 .00936 .00867

5 .01991 .01809 .01648 .01505 .01378 .01265 .01164 .01074 .00993 .00921 6 .02104 .01914 .01746 .01597 .01463 .01345 .01239 .01144 .01059 .00982 7 .02225 .02027 .01851 .01695 .01555 .01430 .01319 .01219 .01130 .01049 8 .02356 .02149 .01965 .01802 .01656 .01525 .01408 .01303 .01209 .01124 9 .02497 .02282 .02090 .01919 .01766 .01629 .01506 .01396 .01296 .01207

10 .02649 .02425 .02224 .02046 .01885 .01742 .01613 .01497 .01392 .01298 11 .02812 .02578 .02369 .02182 .02015 .01865 .01729 .01608 .01498 .01398 12 .02986 .02742 .02525 .02329 .02154 .01997 .01855 .01727 .01612 .01508 13 .03167 .02914 .02687 .02483 .02300 .02135 .01987 .01853 .01732 .01622 14 .03352 .03089 .02852 .02640 .02449 .02276 .02121 .01981 .01854 .01738

15 .03538 .03264 .03018 .02797 .02597 .02417 .02255 .02107 .01974 .01853 16 .03724 .03439 .03183 .02952 .02744 .02556 .02385 .02231 .02092 .01965 17 .03911 .03615 .03348 .03107 .02890 .02694 .02516 .02354 .02208 .02075 18 .04100 .03792 .03515 .03264 .03037 .02832 .02646 .02477 .02323 .02184 19 .04294 .03974 .03685 .03424 .03188 .02973 .02778 .02602 .02441 .02294

20 .04497 .04165 .03864 .03592 .03345 .03121 .02918 .02732 .02564 .02410 21 .04707 .04362 .04049 .03766 .03508 .03275 .03062 .02868 .02691 .02530 22 .04926 .04568 .04243 .03948 .03679 .03435 .03212 .03009 .02824 .02655 23 .05157 .04785 .04447 .04140 .03860 .03605 .03372 .03160 .02965 .02788 24 .05404 .05017 .04666 .04346 .04054 .03788 .03545 .03322 .03119 .02932

25 .05668 .05268 .04902 .04569 .04265 .03987 .03733 .03500 .03287 .03091 26 .05953 .05537 .05157 .04811 .04494 .04204 .03938 .03695 .03472 .03267 27 .06258 .05827 .05433 .05072 .04742 .04440 .04163 .03908 .03674 .03459 28 .06585 .06138 .05729 .05354 .05011 .04695 .04406 .04140 .03895 .03670 29 .06932 .06469 .06044 .05655 .05297 .04969 .04667 .04389 .04132 .03896

30 .07298 .06818 .06378 .05974 .05602 .05260 .04944 .04654 .04386 .04139 31 .07684 .07188 .06732 .06312 .05925 .05569 .05241 .04937 .04657 .04399 32 .08092 .07578 .07106 .06670 .06268 .05898 .05556 .05239 .04947 .04676 33 .08522 .07991 .07501 .07050 .06633 .06247 .05891 .05561 .05256 .04972 34 .08972 .08423 .07917 .07449 .07016 .06615 .06244 .05901 .05582 .05286

35 .09444 .08878 .08354 .07869 .07420 .07004 .06618 .06260 .05928 .05619 36 .09940 .09355 .08814 .08312 .07846 .07415 .07013 .06641 .06294 .05972 37 .10459 .09856 .09297 .08777 .08295 .07847 .07431 .07043 .06682 .06346 38 .11004 .10382 .09805 .09268 .08769 .08304 .07872 .07469 .07093 .06742 39 .11573 .10932 .10337 .09782 .09266 .08784 .08336 .07917 .07526 .07161

May 18, 2009 969 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

40 .12167 .11508 .10893 .10321 .09787 .09289 .08824 .08389 .07982 .07602 41 .12787 .12109 .11476 .10885 .10334 .09818 .09336 .08885 .08463 .08068 42 .13433 .12736 .12085 .11476 .10906 .10373 .09874 .09406 .08968 .08557 43 .14109 .13393 .12723 .12095 .11508 .10957 .10441 .09957 .09502 .09075 44 .14814 .14078 .13389 .12744 .12138 .11569 .11036 .10534 .10063 .09620

45 .15548 .14793 .14086 .13421 .12797 .12211 .11659 .11141 .10653 .10193 46 .16313 .15540 .14814 .14131 .13488 .12884 .12315 .11779 .11274 .10798 47 .17109 .16318 .15573 .14871 .14210 .13588 .13001 .12448 .11925 .11432 48 .17938 .17128 .16364 .15645 .14966 .14325 .13721 .13150 .12610 .12100 49 .18801 .17973 .17191 .16453 .15756 .15098 .14475 .13887 .13330 .12803

50 .19702 .18856 .18057 .17301 .16586 .15910 .15270 .14663 .14089 .13545 51 .20642 .19778 .18961 .18188 .17456 .16762 .16104 .15480 .14889 .14328 52 .21621 .20741 .19907 .19117 .18367 .17656 .16981 .16340 .15732 .15153 53 .22641 .21745 .20894 .20087 .19321 .18593 .17901 .17243 .16617 .16022 54 .23699 .22788 .21922 .21098 .20316 .19571 .18862 .18188 .17546 .16934

55 .24794 .23868 .22987 .22148 .21350 .20589 .19865 .19174 .18516 .17888 56 .25920 .24981 .24085 .23232 .22418 .21642 .20902 .20195 .19521 .18877 57 .27078 .26126 .25217 .24349 .23521 .22730 .21975 .21253 .20563 .19904 58 .28266 .27301 .26379 .25498 .24656 .23851 .23081 .22345 .21640 .20965 59 .29486 .28510 .27576 .26682 .25827 .25009 .24225 .23474 .22755 .22065

60 .30740 .29754 .28810 .27905 .27037 .26206 .25409 .24645 .23911 .23208 61 .32029 .31033 .30079 .29164 .28285 .27442 .26632 .25855 .25109 .24391 62 .33347 .32344 .31381 .30455 .29567 .28712 .27891 .27102 .26343 .25613 63 .34693 .33684 .32713 .31779 .30881 .30017 .29185 .28385 .27614 .26872 64 .36069 .35054 .34076 .33135 .32229 .31356 .30515 .29704 .28922 .28169

65 .37474 .36455 .35472 .34525 .33612 .32731 .31881 .31061 .30270 .29506 66 .38927 .37905 .36919 .35968 .35049 .34161 .33304 .32476 .31676 .30903 67 .40423 .39401 .38413 .37458 .36535 .35643 .34780 .33946 .33138 .32357 68 .41956 .40935 .39947 .38991 .38066 .37170 .36303 .35464 .34650 .33863 69 .43522 .42504 .41518 .40562 .39636 .38739 .37869 .37026 .36208 .35415

70 .45118 .44104 .43121 .42168 .41243 .40346 .39475 .38629 .37809 .37012 71 .46744 .45737 .44759 .43810 .42888 .41992 .41122 .40276 .39455 .38656 72 .48398 .47399 .46429 .45486 .44568 .43676 .42808 .41964 .41143 .40344 73 .50072 .49084 .48123 .47187 .46276 .45389 .44526 .43685 .42866 .42068 74 .51759 .50784 .49833 .48907 .48004 .47124 .46267 .45431 .44616 .43821

75 .53450 .52488 .51550 .50635 .49743 .48872 .48022 .47192 .46383 .45592 76 .55140 .54194 .53270 .52368 .51487 .50626 .49785 .48964 .48161 .47377 77 .56828 .55898 .54990 .54102 .53234 .52385 .51555 .50744 .49950 .49173 78 .58509 .57598 .56707 .55835 .54981 .54146 .53328 .52528 .51744 .50977 79 .60181 .59290 .58417 .57562 .56725 .55904 .55100 .54313 .53541 .52785

80 .61837 .60967 .60114 .59278 .58458 .57653 .56865 .56091 .55333 .54589 81 .63475 .62627 .61795 .60979 .60177 .59391 .58619 .57861 .57117 .56386 82 .65091 .64267 .63457 .62661 .61880 .61112 .60358 .59617 .58888 .58173 83 .66681 .65881 .65094 .64321 .63560 .62812 .62077 .61353 .60642 .59942 84 .68241 .67466 .66703 .65952 .65214 .64487 .63771 .63067 .62373 .61691

85 .69768 .69019 .68280 .67553 .66837 .66132 .65437 .64753 .64078 .63414 86 .71259 .70536 .69822 .69120 .68427 .67744 .67070 .66406 .65752 .65107 87 .72709 .72012 .71325 .70647 .69977 .69317 .68666 .68023 .67389 .66764 88 .74119 .73449 .72787 .72134 .71489 .70852 .70223 .69602 .68989 .68384 89 .75483 .74840 .74204 .73576 .72955 .72342 .71736 .71138 .70546 .69962

90 .76800 .76183 .75573 .74971 .74375 .73785 .73202 .72626 .72056 .71493 91 .78069 .77479 .76895 .76317 .75745 .75180 .74620 .74067 .73519 .72977

2009–20 I.R.B. 970 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

92 .79288 .78724 .78165 .77613 .77065 .76524 .75987 .75456 .74930 .74409 93 .80453 .79915 .79382 .78854 .78331 .77812 .77299 .76790 .76286 .75787 94 .81568 .81055 .80547 .80043 .79544 .79048 .78557 .78071 .77588 .77110

95 .82633 .82144 .81660 .81180 .80704 .80231 .79763 .79298 .78837 .78380 96 .83642 .83177 .82717 .82259 .81806 .81356 .80909 .80465 .80025 .79588 97 .84598 .84157 .83719 .83284 .82853 .82424 .81998 .81576 .81156 .80739 98 .85505 .85086 .84670 .84257 .83847 .83439 .83034 .82631 .82232 .81835 99 .86365 .85968 .85573 .85181 .84791 .84404 .84019 .83636 .83255 .82877

100 .87169 .86792 .86418 .86045 .85675 .85307 .84941 .84577 .84215 .83855 101 .87936 .87579 .87224 .86871 .86520 .86171 .85823 .85477 .85133 .84791 102 .88647 .88309 .87972 .87637 .87304 .86972 .86642 .86313 .85986 .85660 103 .89356 .89036 .88718 .88402 .88086 .87772 .87460 .87149 .86839 .86531 104 .90008 .89706 .89405 .89105 .88807 .88509 .88213 .87918 .87624 .87331

105 .90652 .90366 .90082 .89799 .89517 .89236 .88955 .88676 .88398 .88120 106 .91462 .91199 .90937 .90675 .90414 .90154 .89895 .89636 .89378 .89121 107 .92385 .92147 .91910 .91673 .91437 .91201 .90966 .90731 .90497 .90263 108 .93896 .93702 .93509 .93316 .93123 .92930 .92737 .92544 .92352 .92160 109 .96900 .96800 .96700 .96600 .96500 .96400 .96300 .96200 .96100 .96000

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

0 .01323 .01279 .01238 .01202 .01169 .01139 .01112 .01088 .01065 .01044 1 .00721 .00674 .00632 .00594 .00559 .00528 .00500 .00474 .00451 .00430 2 .00733 .00683 .00639 .00598 .00562 .00529 .00499 .00472 .00447 .00425 3 .00764 .00711 .00664 .00622 .00583 .00548 .00516 .00487 .00461 .00437 4 .00806 .00750 .00700 .00655 .00614 .00577 .00543 .00513 .00485 .00459

5 .00856 .00797 .00744 .00696 .00653 .00614 .00578 .00545 .00515 .00488 6 .00914 .00852 .00795 .00745 .00699 .00657 .00619 .00584 .00552 .00523 7 .00976 .00911 .00851 .00798 .00749 .00704 .00664 .00627 .00593 .00562 8 .01047 .00978 .00915 .00858 .00806 .00759 .00716 .00677 .00640 .00607 9 .01126 .01053 .00986 .00926 .00871 .00821 .00775 .00734 .00695 .00660

10 .01213 .01136 .01065 .01002 .00944 .00891 .00842 .00798 .00757 .00720 11 .01309 .01227 .01153 .01086 .01024 .00968 .00917 .00870 .00827 .00787 12 .01413 .01327 .01249 .01178 .01113 .01054 .00999 .00950 .00904 .00862 13 .01523 .01432 .01350 .01275 .01206 .01144 .01086 .01034 .00985 .00940 14 .01634 .01539 .01452 .01373 .01301 .01235 .01174 .01118 .01067 .01020

15 .01743 .01643 .01552 .01469 .01393 .01323 .01259 .01200 .01146 .01096 16 .01849 .01744 .01648 .01561 .01480 .01407 .01339 .01277 .01220 .01167 17 .01953 .01843 .01742 .01650 .01565 .01488 .01416 .01351 .01290 .01235 18 .02056 .01940 .01834 .01737 .01648 .01566 .01491 .01422 .01358 .01299 19 .02160 .02038 .01927 .01824 .01730 .01644 .01565 .01492 .01424 .01362

20 .02270 .02141 .02024 .01916 .01817 .01726 .01642 .01565 .01494 .01428 21 .02382 .02247 .02124 .02010 .01906 .01810 .01721 .01640 .01565 .01495 22 .02500 .02358 .02228 .02108 .01998 .01897 .01803 .01717 .01638 .01564 23 .02625 .02476 .02339 .02213 .02097 .01990 .01891 .01800 .01716 .01638 24 .02761 .02604 .02460 .02327 .02205 .02092 .01988 .01891 .01802 .01719

25 .02912 .02747 .02595 .02455 .02326 .02206 .02096 .01994 .01900 .01812 26 .03078 .02904 .02744 .02597 .02461 .02335 .02218 .02110 .02010 .01917

May 18, 2009 971 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

27 .03261 .03079 .02910 .02755 .02611 .02478 .02355 .02241 .02135 .02037 28 .03462 .03270 .03093 .02929 .02778 .02637 .02507 .02387 .02274 .02170 29 .03678 .03477 .03291 .03118 .02959 .02811 .02673 .02546 .02427 .02316

30 .03910 .03699 .03503 .03322 .03154 .02997 .02852 .02717 .02592 .02475 31 .04159 .03937 .03731 .03541 .03364 .03199 .03046 .02903 .02770 .02646 32 .04425 .04192 .03976 .03776 .03589 .03416 .03254 .03104 .02963 .02832 33 .04710 .04466 .04239 .04029 .03832 .03650 .03479 .03320 .03172 .03033 34 .05011 .04756 .04518 .04297 .04090 .03898 .03718 .03551 .03394 .03247

35 .05331 .05064 .04815 .04582 .04366 .04163 .03974 .03798 .03632 .03477 36 .05671 .05391 .05130 .04887 .04659 .04446 .04247 .04061 .03887 .03723 37 .06032 .05739 .05466 .05210 .04972 .04748 .04539 .04343 .04159 .03986 38 .06415 .06109 .05823 .05556 .05305 .05070 .04850 .04644 .04450 .04268 39 .06819 .06500 .06201 .05921 .05658 .05412 .05181 .04964 .04760 .04568

40 .07246 .06913 .06601 .06308 .06033 .05774 .05532 .05304 .05089 .04887 41 .07697 .07349 .07023 .06717 .06429 .06158 .05904 .05664 .05439 .05226 42 .08171 .07809 .07469 .07149 .06848 .06564 .06298 .06046 .05809 .05585 43 .08674 .08297 .07942 .07608 .07293 .06997 .06717 .06453 .06204 .05969 44 .09203 .08810 .08441 .08092 .07764 .07454 .07161 .06885 .06624 .06377

45 .09760 .09352 .08967 .08604 .08261 .07938 .07632 .07342 .07068 .06809 46 .10348 .09925 .09524 .09146 .08789 .08451 .08131 .07828 .07542 .07270 47 .10967 .10527 .10111 .09717 .09345 .08992 .08659 .08342 .08042 .07757 48 .11618 .11161 .10730 .10321 .09933 .09566 .09217 .08887 .08573 .08275 49 .12304 .11831 .11383 .10958 .10555 .10173 .09810 .09465 .09137 .08825

50 .13029 .12540 .12076 .11635 .11216 .10818 .10440 .10081 .09739 .09413 51 .13795 .13289 .12808 .12351 .11917 .11504 .11110 .10736 .10379 .10040 52 .14604 .14081 .13584 .13111 .12661 .12232 .11823 .11434 .11062 .10708 53 .15456 .14917 .14404 .13914 .13448 .13004 .12580 .12175 .11789 .11420 54 .16352 .15796 .15266 .14761 .14279 .13819 .13379 .12959 .12558 .12175

55 .17289 .16717 .16171 .15650 .15152 .14676 .14221 .13786 .13370 .12971 56 .18262 .17674 .17113 .16576 .16062 .15570 .15100 .14650 .14218 .13805 57 .19273 .18669 .18092 .17539 .17010 .16503 .16017 .15552 .15105 .14677 58 .20319 .19700 .19107 .18539 .17994 .17472 .16971 .16490 .16029 .15586 59 .21404 .20770 .20162 .19579 .19019 .18481 .17965 .17470 .16993 .16535

60 .22532 .21884 .21261 .20663 .20088 .19536 .19005 .18494 .18003 .17530 61 .23702 .23040 .22403 .21790 .21201 .20634 .20089 .19564 .19058 .18571 62 .24911 .24235 .23584 .22958 .22355 .21774 .21214 .20674 .20154 .19653 63 .26157 .25468 .24805 .24165 .23548 .22954 .22380 .21827 .21293 .20777 64 .27442 .26742 .26065 .25413 .24783 .24175 .23588 .23021 .22474 .21944

65 .28768 .28056 .27368 .26703 .26061 .25441 .24841 .24261 .23700 .23158 66 .30156 .29433 .28735 .28059 .27405 .26773 .26161 .25569 .24995 .24440 67 .31601 .30870 .30161 .29476 .28812 .28169 .27545 .26942 .26357 .25790 68 .33100 .32360 .31643 .30949 .30275 .29622 .28989 .28375 .27779 .27201 69 .34646 .33900 .33177 .32474 .31793 .31131 .30489 .29865 .29259 .28671

70 .36239 .35488 .34758 .34049 .33361 .32692 .32041 .31409 .30795 .30197 71 .37880 .37125 .36391 .35677 .34983 .34308 .33651 .33011 .32389 .31784 72 .39566 .38809 .38073 .37355 .36657 .35977 .35315 .34670 .34041 .33429 73 .41291 .40534 .39796 .39077 .38376 .37693 .37027 .36377 .35744 .35126 74 .43046 .42290 .41552 .40833 .40131 .39446 .38778 .38125 .37489 .36867

75 .44821 .44068 .43332 .42614 .41913 .41227 .40558 .39904 .39266 .38641 76 .46611 .45862 .45130 .44415 .43715 .43031 .42363 .41709 .41069 .40444 77 .48414 .47671 .46944 .46233 .45537 .44856 .44189 .43536 .42898 .42272 78 .50226 .49490 .48770 .48065 .47374 .46697 .46034 .45384 .44747 .44123

2009–20 I.R.B. 972 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

79 .52043 .51317 .50604 .49906 .49222 .48551 .47892 .47247 .46614 .45993

80 .53859 .53142 .52440 .51750 .51074 .50410 .49758 .49118 .48491 .47874 81 .55669 .54964 .54273 .53593 .52926 .52271 .51627 .50995 .50373 .49763 82 .57469 .56778 .56099 .55431 .54774 .54129 .53494 .52871 .52257 .51654 83 .59254 .58577 .57911 .57256 .56612 .55978 .55354 .54740 .54136 .53541 84 .61019 .60358 .59706 .59065 .58434 .57812 .57200 .56597 .56003 .55419

85 .62759 .62114 .61479 .60853 .60236 .59628 .59028 .58438 .57856 .57282 86 .64470 .63843 .63224 .62614 .62012 .61419 .60833 .60256 .59687 .59125 87 .66146 .65537 .64936 .64342 .63757 .63179 .62608 .62045 .61489 .60941 88 .67786 .67196 .66613 .66037 .65469 .64907 .64352 .63804 .63263 .62728 89 .69384 .68813 .68249 .67691 .67140 .66595 .66057 .65525 .64999 .64479

90 .70936 .70385 .69840 .69301 .68768 .68241 .67719 .67204 .66693 .66189 91 .72440 .71909 .71384 .70864 .70349 .69840 .69336 .68837 .68344 .67855 92 .73894 .73383 .72878 .72377 .71881 .71390 .70904 .70422 .69945 .69473 93 .75292 .74801 .74316 .73834 .73357 .72885 .72416 .71952 .71492 .71037 94 .76636 .76166 .75700 .75238 .74780 .74326 .73876 .73429 .72986 .72547

95 .77926 .77476 .77030 .76587 .76148 .75712 .75280 .74851 .74426 .74004 96 .79155 .78725 .78298 .77874 .77453 .77036 .76622 .76210 .75802 .75397 97 .80325 .79915 .79507 .79101 .78699 .78300 .77903 .77509 .77117 .76729 98 .81440 .81048 .80659 .80272 .79887 .79505 .79126 .78749 .78375 .78002 99 .82502 .82128 .81757 .81388 .81021 .80656 .80294 .79934 .79576 .79220

100 .83497 .83141 .82788 .82436 .82086 .81738 .81392 .81048 .80706 .80365 101 .84451 .84112 .83776 .83441 .83107 .82776 .82446 .82117 .81791 .81466 102 .85337 .85014 .84693 .84374 .84056 .83740 .83425 .83112 .82800 .82490 103 .86223 .85918 .85613 .85310 .85008 .84708 .84409 .84111 .83814 .83519 104 .87040 .86749 .86460 .86172 .85885 .85599 .85314 .85030 .84748 .84466

105 .87844 .87568 .87294 .87020 .86748 .86476 .86205 .85935 .85666 .85398 106 .88865 .88609 .88354 .88100 .87846 .87594 .87341 .87090 .86839 .86590 107 .90030 .89797 .89565 .89333 .89102 .88871 .88641 .88411 .88181 .87952 108 .91968 .91776 .91585 .91394 .91203 .91012 .90821 .90630 .90440 .90250 109 .95900 .95800 .95700 .95600 .95500 .95400 .95300 .95200 .95100 .95000

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01025 .01008 .00992 .00977 .00963 .00950 .00938 .00927 .00917 .00907 1 .00410 .00392 .00376 .00361 .00347 .00334 .00322 .00310 .00300 .00290 2 .00404 .00385 .00367 .00351 .00336 .00322 .00310 .00298 .00287 .00276 3 .00415 .00394 .00376 .00359 .00343 .00328 .00314 .00301 .00290 .00279 4 .00435 .00414 .00394 .00375 .00358 .00342 .00328 .00314 .00302 .00290

5 .00463 .00439 .00418 .00398 .00380 .00363 .00348 .00333 .00319 .00307 6 .00496 .00471 .00448 .00427 .00408 .00390 .00373 .00357 .00343 .00329 7 .00533 .00507 .00483 .00460 .00439 .00420 .00402 .00385 .00369 .00355 8 .00577 .00549 .00523 .00499 .00476 .00456 .00436 .00418 .00402 .00386 9 .00627 .00598 .00570 .00544 .00520 .00498 .00478 .00458 .00440 .00423

10 .00685 .00653 .00624 .00596 .00571 .00547 .00525 .00505 .00485 .00467 11 .00750 .00716 .00685 .00656 .00629 .00603 .00580 .00558 .00537 .00518 12 .00823 .00787 .00753 .00722 .00693 .00667 .00642 .00618 .00596 .00576 13 .00899 .00861 .00826 .00793 .00762 .00734 .00707 .00682 .00659 .00637

May 18, 2009 973 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

14 .00976 .00935 .00898 .00863 .00831 .00801 .00772 .00746 .00722 .00698

15 .01050 .01007 .00967 .00931 .00896 .00864 .00835 .00807 .00781 .00756 16 .01118 .01073 .01031 .00992 .00956 .00922 .00891 .00861 .00834 .00808 17 .01183 .01135 .01091 .01050 .01011 .00976 .00942 .00911 .00882 .00855 18 .01244 .01194 .01147 .01104 .01063 .01025 .00990 .00957 .00926 .00897 19 .01304 .01251 .01202 .01156 .01113 .01073 .01035 .01001 .00968 .00937

20 .01367 .01311 .01258 .01209 .01164 .01122 .01082 .01045 .01011 .00978 21 .01430 .01371 .01315 .01263 .01215 .01171 .01129 .01090 .01053 .01019 22 .01496 .01432 .01373 .01319 .01268 .01220 .01176 .01134 .01095 .01059 23 .01565 .01498 .01436 .01377 .01323 .01273 .01225 .01181 .01140 .01101 24 .01642 .01571 .01505 .01443 .01386 .01332 .01282 .01235 .01191 .01149

25 .01731 .01655 .01585 .01519 .01458 .01401 .01347 .01297 .01250 .01206 26 .01831 .01751 .01676 .01606 .01541 .01480 .01423 .01370 .01320 .01273 27 .01945 .01860 .01780 .01706 .01637 .01572 .01511 .01454 .01401 .01351 28 .02073 .01982 .01898 .01819 .01745 .01676 .01611 .01551 .01494 .01440 29 .02213 .02117 .02027 .01943 .01865 .01791 .01722 .01658 .01597 .01540

30 .02365 .02263 .02168 .02079 .01995 .01917 .01844 .01775 .01710 .01649 31 .02531 .02422 .02321 .02226 .02138 .02054 .01976 .01902 .01833 .01768 32 .02709 .02595 .02487 .02387 .02292 .02204 .02120 .02042 .01968 .01899 33 .02903 .02782 .02668 .02561 .02461 .02366 .02278 .02194 .02116 .02041 34 .03110 .02981 .02860 .02747 .02640 .02540 .02446 .02357 .02273 .02194

35 .03332 .03195 .03067 .02947 .02834 .02728 .02627 .02533 .02444 .02359 36 .03569 .03425 .03290 .03162 .03042 .02929 .02823 .02722 .02627 .02537 37 .03824 .03671 .03528 .03393 .03266 .03146 .03032 .02925 .02824 .02729 38 .04097 .03936 .03784 .03641 .03506 .03379 .03259 .03145 .03037 .02936 39 .04387 .04217 .04057 .03905 .03763 .03628 .03500 .03380 .03265 .03157

40 .04696 .04517 .04347 .04187 .04036 .03893 .03758 .03630 .03509 .03394 41 .05025 .04836 .04657 .04488 .04328 .04177 .04034 .03898 .03769 .03647 42 .05374 .05174 .04986 .04807 .04638 .04478 .04326 .04183 .04046 .03917 43 .05747 .05537 .05338 .05150 .04971 .04802 .04641 .04489 .04344 .04207 44 .06143 .05922 .05712 .05514 .05325 .05147 .04977 .04816 .04663 .04517

45 .06564 .06331 .06111 .05901 .05703 .05514 .05335 .05164 .05002 .04848 46 .07012 .06768 .06536 .06315 .06106 .05907 .05718 .05538 .05366 .05203 47 .07487 .07231 .06987 .06755 .06535 .06325 .06125 .05935 .05754 .05581 48 .07992 .07723 .07467 .07223 .06991 .06770 .06560 .06359 .06168 .05985 49 .08529 .08247 .07978 .07722 .07479 .07246 .07024 .06813 .06611 .06418

50 .09103 .08808 .08526 .08258 .08002 .07757 .07524 .07301 .07088 .06885 51 .09716 .09407 .09112 .08831 .08562 .08306 .08060 .07826 .07601 .07387 52 .10370 .10047 .09739 .09445 .09163 .08894 .08637 .08390 .08154 .07928 53 .11068 .10731 .10409 .10101 .09806 .09524 .09254 .08996 .08748 .08510 54 .11808 .11457 .11121 .10800 .10492 .10197 .09914 .09642 .09382 .09133

55 .12590 .12225 .11875 .11540 .11218 .10910 .10614 .10330 .10057 .09795 56 .13409 .13029 .12665 .12316 .11981 .11659 .11350 .11053 .10768 .10493 57 .14266 .13872 .13494 .13130 .12781 .12446 .12123 .11813 .11515 .11228 58 .15160 .14751 .14359 .13981 .13618 .13269 .12933 .12609 .12298 .11998 59 .16095 .15672 .15264 .14873 .14495 .14132 .13783 .13446 .13121 .12808

60 .17076 .16638 .16216 .15810 .15419 .15042 .14678 .14328 .13990 .13663 61 .18101 .17649 .17213 .16793 .16388 .15997 .15619 .15255 .14904 .14564 62 .19169 .18703 .18253 .17818 .17399 .16994 .16603 .16225 .15860 .15507 63 .20279 .19799 .19335 .18886 .18453 .18034 .17629 .17238 .16859 .16493 64 .21433 .20939 .20461 .19998 .19551 .19119 .18700 .18295 .17903 .17523

2009–20 I.R.B. 974 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

65 .22633 .22125 .21633 .21158 .20697 .20251 .19819 .19400 .18994 .18601 66 .23903 .23382 .22877 .22388 .21914 .21455 .21010 .20578 .20159 .19752 67 .25240 .24707 .24190 .23688 .23202 .22730 .22271 .21827 .21395 .20975 68 .26640 .26095 .25566 .25053 .24554 .24070 .23600 .23143 .22698 .22267 69 .28099 .27544 .27004 .26480 .25970 .25474 .24992 .24523 .24067 .23623

70 .29616 .29051 .28501 .27966 .27446 .26939 .26446 .25966 .25499 .25044 71 .31194 .30620 .30062 .29517 .28987 .28471 .27968 .27478 .27000 .26534 72 .32833 .32251 .31684 .31132 .30593 .30068 .29556 .29057 .28569 .28094 73 .34524 .33936 .33363 .32804 .32258 .31725 .31205 .30697 .30201 .29717 74 .36260 .35667 .35089 .34523 .33971 .33432 .32905 .32390 .31887 .31395

75 .38031 .37435 .36852 .36282 .35725 .35180 .34647 .34126 .33617 .33118 76 .39832 .39233 .38647 .38074 .37513 .36964 .36427 .35901 .35386 .34882 77 .41660 .41060 .40473 .39898 .39335 .38783 .38242 .37713 .37194 .36685 78 .43512 .42913 .42326 .41750 .41186 .40632 .40090 .39558 .39036 .38524 79 .45384 .44787 .44201 .43626 .43062 .42509 .41966 .41432 .40909 .40396

80 .47269 .46675 .46092 .45519 .44957 .44404 .43862 .43329 .42806 .42291 81 .49163 .48574 .47994 .47425 .46866 .46316 .45775 .45244 .44722 .44208 82 .51061 .50478 .49904 .49340 .48784 .48238 .47701 .47173 .46653 .46141 83 .52956 .52380 .51813 .51255 .50705 .50165 .49632 .49108 .48592 .48083 84 .54843 .54275 .53716 .53166 .52623 .52089 .51562 .51044 .50532 .50029

85 .56716 .56159 .55609 .55067 .54533 .54006 .53487 .52975 .52470 .51972 86 .58571 .58024 .57485 .56953 .56428 .55910 .55399 .54894 .54397 .53906 87 .60399 .59864 .59337 .58815 .58301 .57793 .57291 .56795 .56306 .55823 88 .62200 .61678 .61162 .60653 .60150 .59653 .59161 .58676 .58196 .57722 89 .63965 .63457 .62954 .62458 .61967 .61481 .61001 .60526 .60057 .59593

90 .65690 .65196 .64707 .64224 .63746 .63273 .62805 .62342 .61884 .61431 91 .67371 .66892 .66418 .65949 .65485 .65025 .64570 .64119 .63673 .63231 92 .69005 .68542 .68083 .67628 .67178 .66732 .66290 .65852 .65419 .64989 93 .70585 .70137 .69694 .69254 .68819 .68387 .67959 .67534 .67114 .66697 94 .72112 .71681 .71253 .70828 .70407 .69990 .69576 .69166 .68759 .68355

95 .73585 .73170 .72758 .72349 .71943 .71541 .71141 .70745 .70352 .69961 96 .74995 .74595 .74199 .73806 .73415 .73027 .72642 .72260 .71881 .71505 97 .76343 .75960 .75579 .75201 .74826 .74453 .74083 .73715 .73350 .72987 98 .77633 .77265 .76900 .76538 .76177 .75819 .75463 .75110 .74759 .74410 99 .78866 .78514 .78165 .77817 .77472 .77129 .76787 .76448 .76111 .75775

100 .80027 .79690 .79356 .79023 .78692 .78363 .78036 .77710 .77386 .77065 101 .81143 .80821 .80502 .80183 .79867 .79552 .79239 .78927 .78617 .78308 102 .82181 .81874 .81568 .81264 .80961 .80659 .80359 .80060 .79763 .79467 103 .83225 .82933 .82641 .82351 .82062 .81774 .81488 .81203 .80919 .80636 104 .84186 .83907 .83629 .83351 .83076 .82801 .82527 .82254 .81982 .81712

105 .85131 .84865 .84600 .84336 .84072 .83810 .83548 .83288 .83028 .82769 106 .86340 .86092 .85844 .85597 .85351 .85105 .84860 .84616 .84372 .84130 107 .87724 .87496 .87268 .87041 .86815 .86589 .86363 .86138 .85914 .85690 108 .90060 .89870 .89681 .89492 .89303 .89114 .88925 .88736 .88548 .88360 109 .94900 .94800 .94700 .94600 .94500 .94400 .94300 .94200 .94100 .94000

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

0 .00898 .00889 .00881 .00873 .00866 .00859 .00853 .00846 .00840 .00835

May 18, 2009 975 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

1 .00281 .00273 .00265 .00257 .00250 .00244 .00237 .00232 .00226 .00221 2 .00267 .00258 .00249 .00241 .00234 .00227 .00220 .00214 .00208 .00202 3 .00268 .00259 .00249 .00241 .00233 .00225 .00218 .00212 .00205 .00199 4 .00279 .00268 .00258 .00249 .00241 .00233 .00225 .00218 .00211 .00205

5 .00295 .00284 .00273 .00263 .00254 .00245 .00237 .00229 .00222 .00215 6 .00316 .00304 .00293 .00283 .00273 .00263 .00254 .00246 .00238 .00230 7 .00341 .00328 .00316 .00305 .00294 .00284 .00274 .00265 .00256 .00248 8 .00371 .00357 .00344 .00332 .00320 .00310 .00299 .00289 .00280 .00271 9 .00408 .00393 .00379 .00366 .00353 .00341 .00330 .00320 .00310 .00300

10 .00450 .00434 .00419 .00405 .00392 .00379 .00367 .00356 .00345 .00335 11 .00500 .00483 .00467 .00452 .00438 .00424 .00411 .00399 .00387 .00376 12 .00557 .00538 .00521 .00505 .00490 .00476 .00462 .00449 .00436 .00425 13 .00617 .00597 .00579 .00562 .00546 .00531 .00516 .00502 .00489 .00477 14 .00677 .00656 .00637 .00619 .00602 .00585 .00570 .00555 .00541 .00528

15 .00733 .00712 .00691 .00672 .00654 .00636 .00620 .00605 .00590 .00576 16 .00784 .00761 .00739 .00719 .00700 .00681 .00664 .00648 .00632 .00618 17 .00829 .00805 .00782 .00761 .00741 .00721 .00703 .00686 .00670 .00654 18 .00870 .00845 .00821 .00798 .00777 .00756 .00737 .00719 .00702 .00685 19 .00909 .00882 .00856 .00832 .00810 .00788 .00768 .00749 .00731 .00713

20 .00948 .00919 .00892 .00867 .00843 .00821 .00799 .00779 .00760 .00741 21 .00986 .00956 .00927 .00901 .00875 .00851 .00829 .00807 .00787 .00767 22 .01024 .00992 .00962 .00933 .00906 .00881 .00857 .00834 .00813 .00792 23 .01065 .01030 .00998 .00968 .00939 .00912 .00887 .00862 .00839 .00818 24 .01110 .01074 .01040 .01007 .00977 .00948 .00921 .00895 .00870 .00847

25 .01165 .01126 .01089 .01055 .01022 .00991 .00962 .00934 .00908 .00884 26 .01228 .01187 .01148 .01111 .01076 .01043 .01012 .00982 .00955 .00928 27 .01303 .01259 .01217 .01178 .01140 .01105 .01072 .01040 .01010 .00982 28 .01390 .01342 .01297 .01255 .01215 .01178 .01142 .01108 .01076 .01046 29 .01486 .01435 .01387 .01342 .01299 .01259 .01221 .01185 .01150 .01117

30 .01591 .01537 .01486 .01437 .01392 .01348 .01307 .01269 .01232 .01197 31 .01707 .01649 .01594 .01542 .01493 .01447 .01403 .01361 .01322 .01284 32 .01833 .01771 .01713 .01657 .01605 .01555 .01508 .01464 .01421 .01381 33 .01971 .01905 .01843 .01784 .01728 .01674 .01624 .01576 .01531 .01487 34 .02119 .02049 .01982 .01919 .01859 .01802 .01748 .01697 .01648 .01602

35 .02280 .02204 .02133 .02065 .02001 .01940 .01883 .01828 .01775 .01726 36 .02452 .02372 .02296 .02224 .02155 .02090 .02028 .01969 .01913 .01860 37 .02638 .02553 .02471 .02394 .02321 .02252 .02185 .02123 .02063 .02006 38 .02839 .02748 .02661 .02579 .02501 .02427 .02356 .02289 .02225 .02164 39 .03055 .02957 .02865 .02777 .02694 .02615 .02539 .02467 .02399 .02333

40 .03285 .03181 .03083 .02990 .02901 .02816 .02735 .02658 .02585 .02515 41 .03531 .03421 .03316 .03217 .03122 .03032 .02946 .02863 .02785 .02710 42 .03793 .03676 .03565 .03459 .03358 .03262 .03170 .03082 .02999 .02919 43 .04076 .03952 .03833 .03721 .03613 .03510 .03413 .03319 .03230 .03144 44 .04378 .04246 .04120 .04000 .03886 .03777 .03672 .03573 .03477 .03386

45 .04701 .04561 .04427 .04299 .04178 .04062 .03950 .03844 .03743 .03645 46 .05047 .04898 .04757 .04621 .04492 .04368 .04250 .04137 .04029 .03925 47 .05416 .05258 .05108 .04964 .04827 .04696 .04570 .04449 .04334 .04224 48 .05810 .05644 .05484 .05332 .05186 .05047 .04913 .04785 .04662 .04545 49 .06233 .06057 .05888 .05727 .05572 .05424 .05282 .05146 .05016 .04890

50 .06690 .06503 .06325 .06154 .05990 .05833 .05683 .05538 .05399 .05266 51 .07181 .06984 .06796 .06615 .06442 .06275 .06116 .05962 .05815 .05673 52 .07712 .07504 .07305 .07114 .06931 .06755 .06585 .06423 .06267 .06116

2009–20 I.R.B. 976 May 18, 2009

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

53 .08282 .08063 .07853 .07652 .07458 .07272 .07093 .06921 .06756 .06596 54 .08893 .08663 .08442 .08229 .08025 .07829 .07640 .07458 .07283 .07114

55 .09544 .09302 .09070 .08846 .08631 .08424 .08224 .08032 .07847 .07669 56 .10230 .09976 .09732 .09497 .09270 .09052 .08842 .08639 .08444 .08256 57 .10952 .10686 .10430 .10183 .09945 .09716 .09495 .09281 .09075 .08877 58 .11709 .11431 .11162 .10904 .10654 .10413 .10181 .09956 .09739 .09530 59 .12506 .12215 .11934 .11663 .11402 .11149 .10905 .10669 .10441 .10221

60 .13349 .13045 .12751 .12468 .12194 .11929 .11674 .11426 .11187 .10955 61 .14236 .13919 .13613 .13317 .13031 .12754 .12486 .12227 .11976 .11733 62 .15166 .14836 .14517 .14208 .13909 .13620 .13340 .13069 .12806 .12551 63 .16138 .15795 .15463 .15141 .14830 .14528 .14235 .13952 .13677 .13410 64 .17155 .16799 .16453 .16119 .15794 .15480 .15175 .14879 .14592 .14313

65 .18220 .17850 .17492 .17144 .16806 .16479 .16161 .15853 .15553 .15262 66 .19358 .18975 .18604 .18243 .17893 .17552 .17222 .16901 .16589 .16285 67 .20568 .20173 .19788 .19415 .19052 .18699 .18356 .18022 .17698 .17382 68 .21847 .21439 .21042 .20656 .20280 .19915 .19560 .19213 .18877 .18549 69 .23191 .22771 .22362 .21964 .21577 .21199 .20831 .20473 .20124 .19784

70 .24601 .24169 .23748 .23339 .22939 .22550 .22171 .21801 .21440 .21088 71 .26080 .25638 .25206 .24785 .24375 .23974 .23584 .23202 .22830 .22467 72 .27630 .27178 .26736 .26305 .25884 .25473 .25071 .24679 .24296 .23922 73 .29244 .28782 .28331 .27890 .27460 .27039 .26628 .26226 .25833 .25449 74 .30914 .30444 .29984 .29535 .29096 .28666 .28245 .27834 .27432 .27038

75 .32630 .32153 .31686 .31229 .30782 .30344 .29915 .29496 .29085 .28682 76 .34389 .33905 .33432 .32968 .32514 .32069 .31633 .31205 .30787 .30376 77 .36187 .35698 .35220 .34750 .34290 .33839 .33396 .32963 .32537 .32120 78 .38022 .37530 .37047 .36573 .36108 .35652 .35204 .34765 .34333 .33910 79 .39891 .39396 .38910 .38433 .37965 .37504 .37053 .36609 .36173 .35744

80 .41786 .41290 .40802 .40323 .39852 .39389 .38934 .38486 .38047 .37615 81 .43703 .43207 .42719 .42238 .41766 .41302 .40845 .40395 .39953 .39518 82 .45638 .45143 .44655 .44175 .43703 .43238 .42781 .42330 .41887 .41450 83 .47583 .47090 .46604 .46126 .45655 .45191 .44734 .44284 .43840 .43403 84 .49532 .49043 .48561 .48085 .47617 .47155 .46700 .46251 .45808 .45372

85 .51480 .50996 .50518 .50047 .49582 .49124 .48671 .48225 .47785 .47351 86 .53421 .52943 .52470 .52004 .51544 .51090 .50642 .50200 .49763 .49332 87 .55346 .54875 .54409 .53950 .53496 .53047 .52604 .52167 .51734 .51307 88 .57254 .56791 .56333 .55881 .55434 .54992 .54555 .54124 .53697 .53275 89 .59134 .58680 .58231 .57788 .57349 .56914 .56485 .56060 .55640 .55225

90 .60982 .60538 .60099 .59665 .59234 .58809 .58388 .57971 .57558 .57150 91 .62794 .62361 .61932 .61508 .61087 .60671 .60259 .59851 .59447 .59046 92 .64564 .64142 .63725 .63311 .62901 .62495 .62093 .61694 .61299 .60907 93 .66284 .65874 .65468 .65066 .64667 .64272 .63880 .63491 .63106 .62724 94 .67955 .67558 .67164 .66773 .66386 .66002 .65621 .65243 .64868 .64496

95 .69574 .69190 .68809 .68431 .68055 .67683 .67313 .66946 .66582 .66221 96 .71131 .70760 .70391 .70025 .69662 .69302 .68944 .68588 .68235 .67885 97 .72626 .72268 .71913 .71560 .71209 .70861 .70515 .70171 .69829 .69490 98 .74063 .73718 .73376 .73035 .72697 .72361 .72027 .71695 .71365 .71037 99 .75442 .75111 .74781 .74454 .74128 .73804 .73483 .73163 .72844 .72528

100 .76744 .76426 .76109 .75794 .75481 .75169 .74860 .74551 .74245 .73940 101 .78001 .77695 .77392 .77089 .76788 .76489 .76191 .75895 .75600 .75306 102 .79172 .78879 .78587 .78297 .78008 .77720 .77434 .77149 .76865 .76582 103 .80354 .80074 .79795 .79517 .79240 .78965 .78690 .78417 .78145 .77874

May 18, 2009 977 2009–20 I.R.B.

Table U(1) - Unitrust Single Life Remainder Factors

Based on Life Table 2000CM Applicable on or After May 1, 2009

Adjusted Payout Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

104 .81442 .81174 .80906 .80640 .80374 .80110 .79847 .79584 .79323 .79063

105 .82511 .82254 .81998 .81742 .81488 .81234 .80982 .80730 .80479 .80229 106 .83887 .83646 .83405 .83165 .82926 .82687 .82449 .82212 .81975 .81739 107 .85466 .85243 .85020 .84798 .84576 .84355 .84134 .83914 .83694 .83474 108 .88172 .87984 .87797 .87610 .87423 .87236 .87049 .86862 .86676 .86490 109 .93900 .93800 .93700 .93600 .93500 .93400 .93300 .93200 .93100 .93000

bles under either paragraph (e)(6) or (f)(6) of this section, the donor or decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) Adjusted payout rate . For transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, the adjusted payout rate is determined by using the appropriate Table F, contained in §1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b). See §1.664–4(e) for rules applicable in determining the adjusted payout rate.

(4) Period is a term of years . If the period described in §1.664–3(a)(5) is a term of years, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, is the factor under the appropriate adjusted payout rate in Table D in §1.664–4(e)(6) corresponding to the number of years in the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the appropriate valuation date) of the property placed in trust by the factor determined under this paragraph. Generally, for purposes of this section, the valuation date

(f) Effective/applicability date . This section applies on or after May 1, 2009.

(g) Expiration date . This section expires on or before May 1, 2012.

Par. 11. The undesignated center heading immediately preceding §1.664–4A is revised to read as follows:

Unitrust Actuarial Tables Applicable

Before May 1, 2009

Par. 12. Section 1.664–4A is amended as follows:

The section heading is revised.
The heading of newly-designated paragraph (f) is revised.
Newly-designated paragraphs (f)(1) and (f)(2) are revised.
New paragraphs (f)(3) and (f)(4) are added.
Newly-designated paragraph (f)(5) is revised.
In newly-designated paragraph (f)(6), the heading and the first paragraph are revised.
The heading of Table U(1) is revised.
Paragraph (f)(7) is added. The additions and revisions read as follows:

§1.664–4A Valuation of charitable remainder interests for which the valuation date is before May 1, 2009 .

- - - (f) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009 —(1) In general . Except as otherwise provided in paragraph (f)(2) of this section, in the case of transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, the present value of a remainder interest is determined under paragraphs (f)(3) through (f)(6) of this section,

provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date under §1.664–3(a)(1)(v) if the taxable year of the trust were to end on such date. See, however, §1.7520–3(b) (relating to exceptions to the use of the prescribed tables under certain circumstances).

(2) Transitional rules for valuation of charitable remainder unitrusts . (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest under this section is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor.

(ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a charitable remainder unitrust for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of a remainder interest based on one or more measuring lives is determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(6) or (f)(6) of this section, at the option of the donor or the decedent’s executor, as the case may be.

(iii) For purposes of paragraphs (f)(2)(i) and (f)(2)(ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial ta

2009–20 I.R.B. 978 May 18, 2009

(2) * * * For transactions with valuation dates after April 30, 1989, and before May 1, 2009, the mortality component tables are contained in §20.2031–7A.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 2.2 and 22 percent for valuation dates after April 30, 1999, and before May 1, 2009 . The following publications are no longer available for purchase from the Superintendent of Documents, United States Government Printing Office; however, they may be obtained from CC:PA:LPD:PR, Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044:

- - - (d) Effective/applicability dates . This section applies after April 30, 1989, and before May 1, 2009.

Par. 14. Section 1.7520–1T is added to read as follows:

§1.7520–1T Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests on or after May 1, 2009 (temporary) .

(a) General actuarial valuations . (1) Except as otherwise provided in this section and in §1.7520–3 (relating to exceptions to the use of prescribed tables under certain circumstances), in the case of certain transactions after April 30, 1989, subject to income tax, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), remainders, and reversions is their present value determined under this section. See §20.2031–7T(d) (and, for certain prior periods, §20.2031–7A) for the computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) For a transfer to a pooled income fund on or after May 1, 2009, see §1.642(c)–6T(e) (or, for certain prior periods, §1.642(c)–6A) with respect to the valuation of the remainder interest.

(3) [Reserved]. For further guidance, see §1.7520–1(a)(3).

is, in the case of an inter vivos transfer, the date on which the property is transferred to the trust by the donor, and, in the case of a testamentary transfer under sections 2055, 2106, or 2624, the valuation date is the date of death. See §1.664–4(e)(4) for additional rules regarding the valuation date. See §1.664–4(e)(4) for an example that illustrates the application of this paragraph (f)(4).

(5) Period is the life of one individual . If the period described in §1.664–3(a)(5) is the life of one individual, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, is the factor in Table U(1) in paragraph (f)(6) of this section under the appropriate adjusted payout. For purposes of the computations described in this paragraph (f)(5), the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The rules provided in §1.664–4T(e)(5) apply for determining the present value of the remainder interest. See §1.664–4T(e)(5) for an example illustrating the application of this paragraph (f)(5) (using current actuarial tables).

(6) Actuarial Table U(1) for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009 . For transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, the present value of a charitable remainder unitrust interest that is dependent on the termination of a life interest is determined by using the section 7520 rate, Table U(1) in this paragraph (f)(6), and Tables F(4.2) through F(14.0) in §1.664–4(e)(6). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuar- ial Values, Book Beth,” (7–1999). Publication 1458 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office. However, pertinent factors in this publication may be obtained by a written request to: CC:PA:LPD:PR (IRS Publication 1458), Room 5205, Internal Revenue

Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.

TABLE U(1).—BASED ON LIFE TABLE 90CM UNITRUST SINGLE

LIFE REMAINDER FACTORS

[Applicable After April 30, 1999,

and Before May 1, 2009]

- - - (7) Effective/applicability dates . Paragraphs (f)(1) through (f)(6) apply after April 30, 1999, and before May 1, 2009.

Par. 13. Section 1.7520–1 is amended by:

Revising the section heading.
Revising paragraphs (a)(1) and (a)(2).
Removing the last two sentences of paragraph (b)(2) and adding a new sentence at the end of the paragraph.
Revising paragraph (c)(1).
Revising the heading and introductory text of paragraph (c)(2).
Revising paragraph (d). The revisions and additions read as follows:

§1.7520–1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests prior to May 1, 2009 .

(a) General actuarial valuations . (1) Except as otherwise provided in this section and in §1.7520–3 (relating to exceptions to the use of prescribed tables under certain circumstances), in the case of certain transactions after April 30, 1989, subject to income tax, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), remainders, and reversions is their present value determined under this section. For periods prior to May 1, 2009, see §20.2031–7A for the computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) For a transfer to a pooled income fund prior to May 1, 2009, see §1.642(c)–6A with respect to the valuation of the remainder interest.

- - - (b) - -

May 18, 2009 979 2009–20 I.R.B.

§20.2031–1 Definition of gross estate; valuation of property.

§20.2031–2 Valuation of stocks and bonds.

§20.2031–3 Valuation of interests in businesses.

§20.2031–4 Valuation of notes. §20.2031–5 Valuation of cash on hand or on deposit.

§20.2031–6 Valuation of household and personal effects.

§20.2031–7 Valuation of annuities, interests for life or term of years, and remainder or reversionary interests.

§20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (temporary).

§20.2031–8 Valuation of certain life insurance and annuity contracts; valuation of shares in an open-end investment company.

§20.2031–9 Valuation of other property.

Actuarial Tables Applicable Before May 1, 2009.

§20.2031–7A Valuation of annuities, interests for life or term of years, and remainder or reversionary interests for estates of decedents for which the valuation date of the gross estate is before May 1, 2009. Par. 17. Section 20.2031–7 is amended as follows:

Revising paragraphs (c), (d)(1), (d)(2), (d)(3), (d)(4), (d)(5), and (e).
Redesignating paragraph (d)(7) as paragraph (f)(4) of §20.2031–7A.
Adding new paragraph (d)(7). The revisions and additions read as follows:

§20.2031–7 Valuation of annuities, interests for life or term of years, and remainder or reversionary interests .

- - - (c) through (d)(5) [Reserved]. For further guidance, see §20.2031–7T(c) through (d)(5).
- - - (7) [Reserved]. For further guidance, see §20.2031–7T(d)(7).

(e) Effective/applicability dates . This section applies after April 30, 1999, and before May 1, 2009.

Par. 18. Section 20.2031–7T is added to read as follows:

(b)(1) [Reserved]. For further guidance, see §1.7520–1(b)(1).

(2) Mortality component . The mortality component reflects the mortality data most recently available from the United States census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the revised mortality component tables will be published in the regulations at that time. For transactions with valuation dates on or after May 1, 2009, the mortality component table (Table 2000CM) is contained in §20.2031–7T(d)(7). See §20.2031–7A for mortality component tables applicable to transactions for which the valuation date falls before May 1, 2009.

(1) Regulation sections containing ta- bles with interest rates between 0.2 and 14 percent for valuation dates on or after May 1, 2009 . Section 1.642(c)–6T(e)(6) contains Table S used for determining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for actuarial factors for one life applicable to valuation dates before May 1, 2009. Section 1.664–4(e)(6) contains Table F (payout factors) and Table D (actuarial factors used in determining the present value of a remainder interest postponed for a term of years). Section 1.664–4T(e)(7) contains Table U(1) (unitrust single life remainder factors). These tables are used in determining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3. See §1.664–4A for unitrust single life remainder factors applicable to valuation dates before May 1, 2009. Section 20.2031–7(d)(6) contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), and Table J (term certain annuity beginningof-interval adjustment factors). Section 20.2031–7T(d)(7) contains Table S (single life remainder factors), and Table 2000CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A for single life remainder factors for one life and mortality components applicable to valuation dates before May 1, 2009.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 0.2 and 22 percent for valuation dates on or after May 1, 2009 . The following documents are available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov :

(i) Internal Revenue Service Publication 1457, “Actuarial Valuations Version 3A” (2009). This publication includes tables of valuation factors, as well as examples that show how to compute other valuation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, measured by one or two lives. These factors may also be used in the valuation of interests in a charitable remainder annuity trust as defined in §1.664–2 and a pooled income fund as defined in §1.642(c)–5.

(ii) Internal Revenue Service Publication 1458, “Actuarial Valuations Version 3B” (2009). This publication includes term certain tables and tables of one and two life valuation factors for determining the present value of remainder interests in a charitable remainder unitrust as defined in §1.664–3.

(iii) Internal Revenue Service Publication 1459, “Actuarial Valuations Version 3C” (2009). This publication includes tables for computing depreciation adjustment factors. See §1.170A–12T.

(d) Effective/applicability date . This section applies on or after May 1, 2009.

(e) Expiration date . This section expires on or before May 1, 2012.

PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954

Par. 15. The authority citation for part 20 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 20.2031–7T also issued under 26 U.S.C. 7520(c)(2). Section 20.7520–1T also issued under 26 U.S.C. 7520(c)(2). - * * Par. 16. Section 20.2031–0 is revised to read as follows:

§20.2031–0 Table of contents .

This section lists the section headings and undesignated center headings that appear in the regulations under section 2031.

2009–20 I.R.B. 980 May 18, 2009

ders, and reversions for estates of decedents for which the valuation date of the gross estate is before May 1, 2009, is determined under the following sections:

§20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (temporary) .

(a) through (b) [Reserved]. For further information, see §20.2031–7(a) through (b).

(c) Actuarial valuations . The present value of annuities, life estates, terms of years, remainders, and reversions for estates of decedents for which the valuation date of the gross estate is on or after May 1, 2009, is determined under paragraph (d) of this section. The present value of annuities, life estates, terms of years, remain

Valuation Dates

After Before Applicable Regulations

01–01–52 20.2031–7A(a) 12–31–51 01–01–71 20.2031–7A(b) 12–31–70 12–01–83 20.2031–7A(c) 11–30–83 05–01–89 20.2031–7A(d) 04–30–89 05–01–99 20.2031–7A(e) 04–30–99 05–01–09 20.2031–7A(f)

period). Internal Revenue Service Publication 1457 includes actuarial factors for a remainder interest after a term of years in Table B and after the life of one individual in Table S (for one measuring life when the valuation date is on or after May 1, 2009). However, term-of-years and life interest actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in paragraph (d)(7) of this section (or in §20.2031–7A). If Internal Revenue Service Publication 1457 (or any other reliable source of term-of-years and life interest actuarial factors) is not conveniently available, an actuarial factor for the interest may be derived mathematically. This actuarial factor may be derived by subtracting the correlative remainder factor (that corresponds to the applicable section 7520 interest rate and the term of years or the life) in Table B (for a term of years) in §20.2031–7(d)(6) or in Table S (for the life of one individual) in paragraph (d)(7) of this section, as the case may be, from 1.000000. For information about obtaining actuarial factors for other types of term-of-years and life interests, see paragraph (d)(4) of this section.

(iv) Annuities . (A) If the interest to be valued is the right of a person to receive an annuity that is payable at the end of each year for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the aggregate amount payable annually by the appropriate annuity actuarial factor (that corresponds to the applicable section 7520 interest rate and annuity pe

(d) Actuarial valuations on or after May 1, 2009 —(1) In general . Except as otherwise provided in paragraph (b) of this section and §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date for the gross estate of the decedent is on or after May 1, 2009, the fair market value of annuities, life estates, terms of years, remainders, and reversionary interests is the present value determined by use of standard or special section 7520 actuarial factors. These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality component for the valuation date of the interest that is being valued. For purposes of the computations described in this section, the age of an individual is the age of that individual at the individual’s nearest birthday. See §§20.7520–1 through 20.7520–4.

(2) Specific interests —(i) Charitable remainder trusts . The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5, is its value determined under §1.642(c)–6T(e). The fair market value of a remainder interest in a charitable remainder annuity trust, as defined in §1.664–2(a), is the present value determined under §1.664–2(c). The fair market value of a remainder interest in a charitable remainder unitrust, as defined in §1.664–3, is its present value determined under §1.664–4T(e). The fair market value of a life interest or term of years in a charitable remainder unitrust is the fair market value of the property as of the date of valuation less the fair market

value of the remainder interest on that date determined under §1.664–4T(e)(4) and (5).

(ii) Ordinary remainder and reversion- ary interests . If the interest to be valued is to take effect after a definite number of years or after the death of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate remainder interest actuarial factor (that corresponds to the applicable section 7520 interest rate and remainder interest period) in Table B (for a term certain) or the appropriate Table S (for one measuring life), as the case may be. Table B is contained in §20.2031–7(d)(6) and Table S (for one measuring life when the valuation date is on or after May 1, 2009) is contained in paragraph (d)(7) of this section and in Internal Revenue Service Publication 1457. See §20.2031–7A containing Table S for valuation of interests before May 1, 2009. For information about obtaining actuarial factors for other types of remainder interests, see paragraph (d)(4) of this section.

May 18, 2009 981 2009–20 I.R.B.

§20.2031–7A(f)(4), at the option of the decedent’s executor.

(iii) For purposes of paragraphs (d)(3)(i) and (d)(3)(ii) of this section, where the decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (d)(7) of this section or §20.2031–7A(f)(4), the decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(4) Publications and actuarial compu- tations by the Internal Revenue Service . Many standard actuarial factors not included in §20.2031–7(d)(6) or in paragraph (d)(7) of this section are included in Internal Revenue Service Publication 1457, “ Actuarial Valuations Version 3A ” (2009). Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. This publication will be available beginning May 1, 2009, at no charge, electronically via the Internal Revenue Service Internet site at www.irs.gov . If a special factor is required in the case of an actual decedent, the Internal Revenue Service may furnish the factor to the executor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the decedent’s death, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)( b )) and include payment of the required user fee.

(5) Examples . The provisions of this section are illustrated by the following examples:

Example 1 . Remainder payable at an individual’s death . The decedent, or the decedent’s estate, was entitled to receive certain property worth $50,000 upon the death of A, to whom the income was bequeathed for life. At the time of the decedent’s death, A was 47 years and 5 months old. In the month in which the decedent died, the section 7520 rate was 6.2 percent. Under Table S in paragraph (d)(7) of this section,

riod). Internal Revenue Publication 1457 includes actuarial factors for a remainder interest in Table B (after an annuity payable for a term of years) and in Table S (after an annuity payable for the life of one individual when the valuation date is on or after May 1, 2009). However, annuity actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in paragraph (d)(7) of this section (or in §20.2031–7A). If Internal Revenue Service Publication 1457 (or any other reliable source of annuity actuarial factors) is not conveniently available, a required annuity factor for a term of years or for one life may be mathematically derived. This annuity factor may be derived by subtracting the applicable remainder factor (that corresponds to the applicable section 7520 interest rate and annuity period) in Table B (in the case of a term-of-years annuity) in §20.2031–7(d)(6) or in Table S (in the case of a one-life annuity when the valuation date is on or after May 1, 2009) in paragraph (d)(7) of this section, as the case may be, from 1.000000 and then dividing the result by the applicable section 7520 interest rate expressed as a decimal number.

(B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiplying the annuity factor by the aggregate amount payable annually is then multiplied by the applicable adjustment factor as contained in Table K in §20.2031–7(d)(6) for payments made at the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the following example:

Example . At the time of the decedent’s death, the survivor/annuitant, age 72, is entitled to receive an annuity of $15,000 a year for life payable in equal monthly installments at the end of each period. The section 7520 rate for the month in which the decedent died is 5.6 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 5.6 percent for an individual aged 72 is .53243. By converting the remainder factor to an annuity factor, as described above, the annuity factor at 5.6 percent for an individual aged 72 is 8.3495 (1.00000 minus .53243, divided by .056). Under Table K in §20.2031–7(d)(6), the adjustment factor under the column for payments made at the end of each monthly period at the rate of 5.6 percent is 1.0254. The aggregate annual amount, $15,000, is multiplied by the factor 8.3495 and the product multiplied by 1.0254. The present value of the annuity at the date of the decedent’s death is, therefore, $128,423.66 ($15,000 x 8.3495 x 1.0254).

monthly, or weekly periods for a term of years, the value of the annuity is computed by multiplying the aggregate amount payable annually by the annuity factor described in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Table J in §20.2031–7(d)(6) at the appropriate interest rate component for payments made at the beginning of specified periods. If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment plus the present value of a similar annuity, the first payment of which is not to be made until the end of the payment period, determined as provided in this paragraph (d)(2)(iv).

(v) Annuity and unitrust interests for a term of years or until the prior death of an individual . See §25.2512–5T(d)(2)(v) for examples explaining how to compute the present value of an annuity or unitrust interest that is payable until the earlier of the lapse of a specific number of years or the death of an individual.

(3) Transitional rule . (i) If a decedent dies on or after May 1, 2009, and if on May 1, 2009, the decedent was mentally incompetent so that the disposition of the decedent’s property could not be changed, and the decedent dies without having regained competency to dispose of the decedent’s property or dies within 90 days of the date on which the decedent first regains competency, the fair market value of annuities, life estates, terms for years, remainders, and reversions included in the gross estate of the decedent is their present value determined either under this section or under the corresponding section applicable at the time the decedent became mentally incompetent, at the option of the decedent’s executor. For examples, see §20.2031–7A(d).

(ii) If a decedent dies on or after May 1, 2009, and before July 1, 2009, the fair market value of annuities, life estates, remainders, and reversions based on one or more measuring lives included in the gross estate of the decedent is their present value determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§20.7520–1(b) and 20.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (d)(7) of this section or

2009–20 I.R.B. 982 May 18, 2009

the remainder factor at 6.2 percent for determining the present value of the remainder interest due at the death of a person aged 47, the number of years nearest A’s actual age at the decedent’s death, is .18672. The present value of the remainder interest at the date of the decedent’s death is, therefore, $9,336.00 ($50,000 X .18672).

Example 2. Income payable for an individual’s life . A’s parent bequeathed an income interest in property to A for life, with the remainder interest passing to B at A’s death. At the time of the parent’s death, the value of the property was $50,000 and A was 30 years and 10 months old. The section 7520 rate at the time of the parent’s death was 6.2 percent. Under Table S in paragraph (d)(7) of this section, the remainder factor at 6.2 percent for determining the present value of the remainder interest due at the death of a person aged 31, the number of years closest to A’s age at the decedent’s death, is .08697. Converting this remainder factor to an income factor, as described in paragraph (d)(2)(iii) of this section, the factor for determining the present value of an income interest for the life of a person aged 31 is .91303. The present value of A’s interest at the time of the parent’s death is, therefore, $45,651.50 ($50,000 X .91303).

Example 3. Annuity payable for an individual’s life . A purchased an annuity for the benefit of both A and B. Under the terms of the annuity contract, at A’s death, a survivor annuity of $10,000 per year payable in equal semiannual installments made at the end of

each interval is payable to B for life. At A’s death, B was 45 years and 7 months old. Also, at A’s death, the section 7520 rate was 4.8 percent. Under Table S in paragraph (d)(7) of this section, the factor at 4.8 percent for determining the present value of the remainder interest at the death of a person age 46 (the number of years nearest B’s actual age) is .24774. By converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity payable until the death of a person age 46 is 15.6721 (1.00000 minus .24774, divided by .048). The adjustment factor from Table K in §20.2031–7(d)(6) at an interest rate of 4.8 percent for semiannual annuity payments made at the end of the period is 1.0119. The present value of the annuity at the date of A’s death is, therefore, $158,585.98 ($10,000 X 15.6721 X 1.0119).

Example 4 . Annuity payable for a term of years. The decedent, or the decedent’s estate, was entitled to receive an annuity of $10,000 per year payable in equal quarterly installments at the end of each quarter throughout a term certain. At the time of the decedent’s death, the section 7520 rate was 9.8 percent. A quarterly payment had just been made prior to the decedent’s death and payments were to continue for 5 more years. Under Table B in §20.2031–7(d)(6) for the interest rate of 9.8 percent, the factor for the present value of a remainder interest due after a term of 5 years is .626597. Converting the factor to an annuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

annuity for a term of 5 years is 3.8102 (1.00000 minus .626597, divided by .098). The adjustment factor from Table K in §20.2031–7(d)(6) at an interest rate of 9.8 percent for quarterly annuity payments made at the end of the period is 1.0360. The present value of the annuity is, therefore, $39,473.67 ($10,000 X 3.8102 X 1.0360). (6) [Reserved]. For further guidance, see §20.2031–7(d)(6).

(7) Actuarial Table S and Table 2000CM where the valuation date is on or after May 1, 2009 . Except as provided in §20.7520–2(b) (pertaining to certain limitations on the use of prescribed tables), for determination of the present value of an interest that is dependent on the termination of a life interest, Table 2000CM and Table S (single life remainder factors applicable where the valuation date is on or after May 1, 2009) contained in this paragraph (d)(7) and Table J and Table K contained in §20.2031–7(d)(6), must be used in the application of the provisions of this section when the section 7520 interest rate component is between 0.2 and 14 percent.

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

May 18, 2009 983 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

24 .89808 .80737 .72658 .65456 .59031 .53295 .48169 .43586 .39484 .35809

30 .90837 .82591 .75165 .68473 .62438 .56990 .52070 .47623 .43601 .39959 31 .91010 .82904 .75592 .68989 .63024 .57631 .52751 .48333 .44329 .40698 32 .91182 .83218 .76020 .69509 .63616 .58278 .53440 .49052 .45068 .41449 33 .91355 .83532 .76449 .70031 .64212 .58931 .54137 .49780 .45818 .42213 34 .91527 .83847 .76880 .70556 .64811 .59589 .54839 .50516 .46578 .42988

2009–20 I.R.B. 984 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 0.2% 0.4% 0.6% 0.8% 1.0% 1.2% 1.4% 1.6% 1.8% 2.0%

74 .97695 .95466 .93310 .91223 .89202 .87247 .85353 .83518 .81741 .80019

80 .98337 .96717 .95138 .93598 .92098 .90635 .89208 .87817 .86460 .85135 81 .98431 .96901 .95408 .93951 .92529 .91141 .89786 .88463 .87172 .85910 82 .98521 .97077 .95667 .94290 .92944 .91629 .90344 .89088 .87861 .86660 83 .98608 .97247 .95917 .94616 .93343 .92099 .90882 .89691 .88526 .87385 84 .98691 .97409 .96156 .94928 .93727 .92551 .91399 .90271 .89166 .88084

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

5 .21984 .19324 .17013 .15004 .13255 .11730 .10399 .09237 .08220 .07329 6 .22454 .19773 .17440 .15408 .13636 .12089 .10736 .09553 .08515 .07605

May 18, 2009 985 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

7 .22933 .20233 .17879 .15824 .14030 .12460 .11085 .09880 .08822 .07892 8 .23425 .20705 .18330 .16254 .14436 .12844 .11447 .10221 .09142 .08193 9 .23930 .21191 .18795 .16697 .14857 .13243 .11824 .10576 .09476 .08507

2009–20 I.R.B. 986 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

58 .61978 .59517 .57182 .54964 .52858 .50858 .48956 .47147 .45427 .43790 59 .63007 .60589 .58290 .56105 .54027 .52050 .50167 .48375 .46668 .45041

65 .69186 .67053 .65009 .63049 .61170 .59367 .57637 .55976 .54381 .52849 66 .70216 .68136 .66140 .64223 .62383 .60615 .58916 .57283 .55713 .54203 67 .71250 .69224 .67277 .65405 .63605 .61874 .60208 .58605 .57062 .55575 68 .72283 .70312 .68416 .66590 .64833 .63140 .61509 .59938 .58423 .56963 69 .73312 .71398 .69553 .67776 .66062 .64409 .62815 .61277 .59793 .58360

May 18, 2009 987 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 2.2% 2.4% 2.6% 2.8% 3.0% 3.2% 3.4% 3.6% 3.8% 4.0%

108 .97859 .97670 .97482 .97295 .97109 .96923 .96739 .96555 .96373 .96191 109 .98924 .98828 .98733 .98638 .98544 .98450 .98356 .98263 .98170 .98077

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

40 .23493 .22137 .20878 .19707 .18619 .17606 .16663 .15784 .14965 .14201

2009–20 I.R.B. 988 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

41 .24322 .22950 .21674 .20487 .19381 .18350 .17390 .16493 .15656 .14873 42 .25173 .23786 .22494 .21290 .20168 .19120 .18141 .17227 .16372 .15572 43 .26049 .24648 .23342 .22122 .20982 .19918 .18922 .17990 .17118 .16301 44 .26950 .25535 .24214 .22979 .21824 .20742 .19730 .18781 .17892 .17057

90 .83967 .83324 .82690 .82065 .81450 .80843 .80244 .79655 .79073 .78500 91 .84898 .84288 .83685 .83091 .82505 .81928 .81358 .80795 .80241 .79693

May 18, 2009 989 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0%

92 .85787 .85208 .84636 .84072 .83515 .82966 .82423 .81888 .81360 .80838 93 .86632 .86083 .85541 .85006 .84477 .83955 .83440 .82931 .82428 .81931 94 .87435 .86915 .86402 .85894 .85393 .84898 .84409 .83925 .83447 .82975

100 .91397 .91028 .90663 .90301 .89942 .89587 .89234 .88885 .88539 .88196 101 .91930 .91583 .91238 .90897 .90558 .90223 .89890 .89560 .89233 .88908 102 .92424 .92096 .91771 .91448 .91128 .90811 .90496 .90184 .89875 .89568 103 .92914 .92605 .92300 .91996 .91695 .91397 .91100 .90806 .90514 .90225 104 .93364 .93074 .92786 .92501 .92217 .91935 .91656 .91379 .91103 .90830

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

2009–20 I.R.B. 990 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

75 .55253 .54361 .53492 .52645 .51820 .51015 .50230 .49465 .48719 .47991

May 18, 2009 991 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0%

76 .56912 .56036 .55182 .54349 .53536 .52742 .51968 .51213 .50475 .49754 77 .58565 .57706 .56868 .56050 .55251 .54471 .53708 .52964 .52236 .51525 78 .60209 .59369 .58549 .57747 .56963 .56197 .55448 .54715 .53999 .53298 79 .61841 .61021 .60219 .59435 .58668 .57917 .57182 .56463 .55760 .55071

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

2009–20 I.R.B. 992 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

9 .01407 .01321 .01242 .01170 .01104 .01044 .00989 .00938 .00891 .00848

15 .02123 .02007 .01901 .01803 .01714 .01632 .01556 .01485 .01420 .01360 16 .02247 .02126 .02015 .01913 .01818 .01732 .01652 .01578 .01509 .01446 17 .02371 .02244 .02127 .02020 .01921 .01830 .01746 .01668 .01596 .01529 18 .02494 .02361 .02239 .02126 .02022 .01926 .01838 .01756 .01680 .01610 19 .02620 .02480 .02352 .02234 .02125 .02024 .01931 .01844 .01764 .01690

May 18, 2009 993 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0%

59 .23553 .22935 .22341 .21770 .21221 .20693 .20185 .19696 .19225 .18772

65 .31148 .30468 .29812 .29177 .28563 .27969 .27394 .26837 .26299 .25777 66 .32564 .31877 .31213 .30570 .29948 .29345 .28761 .28195 .27647 .27115 67 .34034 .33341 .32671 .32021 .31391 .30780 .30188 .29614 .29057 .28517 68 .35552 .34855 .34179 .33523 .32887 .32270 .31671 .31089 .30524 .29976 69 .37115 .36414 .35734 .35073 .34432 .33809 .33204 .32616 .32045 .31489

2009–20 I.R.B. 994 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

0 .01132 .01110 .01089 .01071 .01053 .01037 .01022 .01008 .00995 .00983 1 .00520 .00497 .00476 .00457 .00439 .00423 .00407 .00393 .00379 .00367 2 .00521 .00496 .00474 .00454 .00435 .00417 .00401 .00385 .00371 .00358 3 .00539 .00513 .00490 .00468 .00447 .00429 .00411 .00395 .00380 .00366 4 .00567 .00540 .00515 .00492 .00470 .00450 .00432 .00414 .00398 .00383

May 18, 2009 995 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

50 .10711 .10403 .10109 .09827 .09558 .09300 .09053 .08816 .08589 .08371 51 .11392 .11072 .10765 .10472 .10191 .09921 .09663 .09415 .09178 .08950 52 .12116 .11783 .11464 .11159 .10866 .10585 .10315 .10057 .09808 .09569 53 .12883 .12538 .12206 .11889 .11584 .11291 .11010 .10740 .10481 .10231 54 .13694 .13336 .12992 .12662 .12345 .12041 .11748 .11467 .11196 .10936

100 .81641 .81357 .81075 .80796 .80518 .80243 .79971 .79700 .79432 .79165

2009–20 I.R.B. 996 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0%

101 .82683 .82412 .82144 .81877 .81612 .81350 .81089 .80831 .80574 .80320 102 .83652 .83394 .83137 .82882 .82630 .82379 .82130 .81883 .81637 .81394 103 .84624 .84379 .84135 .83892 .83652 .83413 .83176 .82941 .82707 .82475 104 .85519 .85285 .85053 .84822 .84593 .84365 .84139 .83915 .83692 .83470

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

May 18, 2009 997 2009–20 I.R.B.

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

34 .02707 .02624 .02545 .02470 .02399 .02331 .02267 .02205 .02146 .02091

35 .02905 .02817 .02733 .02653 .02577 .02505 .02436 .02371 .02308 .02249 36 .03117 .03024 .02935 .02850 .02769 .02693 .02619 .02550 .02483 .02419 37 .03345 .03246 .03151 .03061 .02976 .02894 .02816 .02742 .02671 .02603 38 .03590 .03485 .03385 .03289 .03198 .03112 .03029 .02950 .02874 .02802 39 .03852 .03740 .03634 .03533 .03436 .03344 .03256 .03172 .03092 .03015

2009–20 I.R.B. 998 May 18, 2009

Table S Based on Life Table 2000CM Single Life Remainder Factors Applicable on or After May 1, 2009

Interest Rate

AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0%

84 .52966 .52537 .52115 .51700 .51291 .50887 .50490 .50099 .49714 .49334

85 .54870 .54448 .54032 .53622 .53218 .52820 .52428 .52041 .51660 .51284 86 .56759 .56344 .55935 .55532 .55135 .54742 .54356 .53974 .53598 .53227 87 .58626 .58219 .57818 .57422 .57031 .56646 .56266 .55891 .55521 .55155 88 .60468 .60070 .59677 .59290 .58907 .58529 .58157 .57788 .57425 .57066 89 .62277 .61888 .61505 .61126 .60753 .60383 .60018 .59658 .59302 .58950

Table 2000CM Age Age Age

x l x l x l x x x 0 100000 37 96921 74 66882 1 99305 38 96767 75 64561 2 99255 39 96600 76 62091 3 99222 40 96419 77 59476 4 99197 41 96223 78 56721 5 99176 42 96010 79 53833 6 99158 43 95782 80 50819 7 99140 44 95535 81 47694 8 99124 45 95268 82 44475 9 99110 46 94981 83 41181 10 99097 47 94670 84 37837 11 99085 48 94335 85 34471 12 99073 49 93975 86 31114 13 99057 50 93591 87 27799 14 99033 51 93180 88 24564 15 98998 52 92741 89 21443 16 98950 53 92270 90 18472 17 98891 54 91762 91 15685 18 98822 55 91211 92 13111 19 98745 56 90607 93 10773 20 98664 57 89947 94 8690 21 98577 58 89225 95 6871

May 18, 2009 999 2009–20 I.R.B.

Table 2000CM Age Age Age

22 98485 59 88441 96 5315 23 98390 60 87595 97 4016 24 98295 61 86681 98 2959 25 98202 62 85691 99 2122 26 98111 63 84620 100 1477 27 98022 64 83465 101 997 28 97934 65 82224 102 650 29 97844 66 80916 103 410 30 97750 67 79530 104 248 31 97652 68 78054 105 144 32 97549 69 76478 106 81 33 97441 70 74794 107 43 34 97324 71 73001 108 22 35 97199 72 71092 109 11 36 97065 73 69056 110 0

ket value of annuities, life estates, remainders, and reversions based on one or more measuring lives included in the gross estate of the decedent is their present value determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§20.7520–1(b) and 20.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(4) or paragraph (f)(4) of this section, at the option of the decedent’s executor.

(iii) For purposes of paragraphs (f)(2)(i) and (f)(2)(ii) of this section, where the decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(4) or paragraph (f)(4) of this section, the decedent’s executor must use the same actuarial table with respect to each individual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables).

(3) Publications and actuarial compu- tations by the Internal Revenue Service . Many standard actuarial factors not included in paragraph (f)(4) of this section or in §20.2031–7(d)(6) are included in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (7–99). Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government

(e) Effective/applicability date . This section applies on or after May 1, 2009.

(f) Expiration date . This section expires on or before May 1, 2012.

Par. 19. The undesignated center heading immediately preceding §20.2031–7A is revised to read as follows:

Actuarial Tables Applicable Before

May 1, 2009

Par. 20. Section 20.2031–7A is amended by:

Revising the section heading.
Adding paragraphs (f)(1), (f)(2), and (f)(3).
In newly-designated paragraph (f)(4), the heading and introductory text paragraph is revised.
The heading of Table S in newlydesignated paragraph (f)(4) is revised.
The heading of Table 90CM in newly-designated paragraph (f)(4) is revised.
Paragraph (f)(5) is added. The revisions and additions read as follows:

§20.2031–7A Valuation of annuities, interests for life or term of years, and remainder or reversionary interests for estates of decedents for which the valuation date of the gross estate is before May 1, 2009 .

- - - (f) Valuation of annuities, interests for life or term of years, and remainder or reversionary interests for estates of dece- dents for which the valuation date of the gross estate is after April 30,1999, and be- fore May 1, 2009 —(1) In general . Except

as otherwise provided in §20.2031–7(b) and §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date for the gross estate of the decedent is after April 30, 1999, and before May 1, 2009, the fair market value of annuities, life estates, terms of years, remainders, and reversionary interests is the present value of the interests determined by use of standard or special section 7520 actuarial factors and the valuation methodology described in §20.2031–7T(d). These factors are derived by using the appropriate section 7520 interest rate and, if applicable, the mortality component for the valuation date of the interest that is being valued. See §§20.7520–1 through 20.7520–4. See paragraph (f)(4) of this section for determination of the appropriate table for use in valuing these interests.

(2) Transitional rule . (i) If a decedent dies after April 30, 1999, and if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the decedent’s property could not be changed, and the decedent dies without having regained competency to dispose of the decedent’s property or dies within 90 days of the date on which the decedent first regains competency, the fair market value of annuities, life estates, terms for years, remainders, and reversions included in the gross estate of the decedent is their present value determined either under this section or under the corresponding section applicable at the time the decedent became mentally incompetent, at the option of the decedent’s executor. For example, see paragraph (d) of this section.

(ii) If a decedent dies after April 30, 1999, and before July 1, 1999, the fair mar

2009–20 I.R.B. 1000 May 18, 2009

(3) Effective/applicability date . - * * (iii) [Reserved]. For further guidance, see §20.2055–2T(e)(3)(iii).

- - - (f) - - (4) [Reserved]. For further guidance, see §20.2055–2T(f)(4).
- - - Par. 24. Section 20.2055–2T is added to read as follows:

§20.2055–2T Transfers not exclusively for charitable purposes (temporary) .

(a) through (e)(3)(ii). [Reserved]. For further guidance, see §20.2055–2(a) through (e)(3)(ii).

(e)(3)(iii) The rule in paragraphs (e)(2)(vi)(a) and (e)(2)(vii)(a) of this section that guaranteed annuity interests or unitrust interests, respectively, may be payable for a specified term of years or for the life or lives of only certain individuals is generally effective in the case of transfers pursuant to wills and revocable trusts when the decedent dies on or after April 4, 2000. Two exceptions from the application of this rule in paragraphs (e)(2)(vi)(a) and (e)(2)(vii)(a) of this section are provided in the case of transfers pursuant to a will or revocable trust executed on or before April 4, 2000. One exception is for a decedent who dies on or before July 5, 2001, without having republished the will (or amended the trust) by codicil or otherwise. The other exception is for a decedent who was on April 4, 2000, under a mental disability that prevented a change in the disposition of the decedent’s property, and who either does not regain competence to dispose of such property before the date of death, or dies prior to the later of 90 days after the date on which the decedent first regains competence, or July 5, 2001, without having republished the will (or amended the trust) by codicil or otherwise. If a guaranteed annuity interest or unitrust interest created pursuant to a will or revocable trust when the decedent dies on or after April 4, 2000, uses an individual other than one permitted in paragraphs (e)(2)(vi)(a) and (vii)(a) of this section, and the interest does not qualify for this transitional relief, the interest may be reformed into a lead interest payable for a specified term of years. The term of years is determined by

Printing Office. However, pertinent factors in this publication may be obtained from: CC:PA:LPD:PR (IRS Publication 1457), Room 5205, Internal Revenue Service, P.O.Box 7604, Ben Franklin Station, Washington, DC 20044. If a special factor is required in the case of an actual decedent, the Internal Revenue Service may furnish the factor to the executor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the decedent’s death, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)( b )) and include payment of the required user fee.

(4) Actuarial tables . Except as provided in §20.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), Life Table 90CM and Table S (Single life remainder factors applicable where the valuation date is after April 30, 1999, and before May 1, 2009), contained in this paragraph (f)(4), and Table B, Table J, and Table K set forth in §20.2031–7(d)(6) must be used in the application of the provisions of this section when the section 7520 interest rate component is between 4.2 and 14 percent. Table S and Table 90CM are as follows:

Table S.—Based on Life on Life Table

90CM Single Life Remainder Factors

[Applicable After April 30, 1999,

and Before May 1, 2009]

Table 90 CM.—Applicable After April

30, 1999, and Before May 1, 2009

- - - (5) Effective/applicability dates . Paragraphs (f)(1) through (f)(4) apply after April 30, 1999, and before May 1, 2009.

Par. 21. Section 20.2032–1 is amended by revising paragraph (f)(1) as follows:

§20.2032–1 Alternate Valuation .

- - - (f) - - (1) [Reserved]. For further guidance, see §20.2032–1T(f)(1).
- - - Par. 22. Section 20.2032–1T is added to read as follows:

§20.2032–1T Alternate Valuation (temporary) .

(a) through (e) [Reserved]. For further guidance, see §20.2032–1(a) through (e).

(f) [Reserved]. For further guidance, see §20.2032–1(f).

(1) Life estates, remainders, and sim- ilar interests . The values of life estates, remainders, and similar interests are to be obtained by applying the methods prescribed in §20.2031–7, using (i) the age of each person, the duration of whose life may affect the value of the interest, as of the date of the decedent’s death, and (ii) the value of the property as of the alternate valuation date. For example, assume that the decedent, or the decedent’s estate, was entitled to receive certain property worth $50,000 upon the death of A, who was entitled to the income for life. At the time of the decedent’s death, on or after May 1, 2009, A was 47 years and 5 months old. In the month in which the decedent died, the section 7520 rate was 6.2 percent. The value of the decedent’s remainder interest at the date of the decedent’s death would, as illustrated in Exam- ple 1 of §20.2031–7T(d)(5), be $9,336.00 ($50,000 x .18672). If, because of economic conditions, the property declined in value and was worth only $40,000 on the date that was 6 months after the date of the decedent’s death, the value of the remainder interest would be $7,468.80 ($40,000 X .18672), even though A would be 48 years old on the alternate valuation date.

(f)(2) through (g) [Reserved]. For further guidance, see §20.2032–1(f)(2) through (g).

(h) Effective/applicability date . Paragraph (f)(1) applies on or after May 1, 2009. (i) Expiration date . Paragraph (f)(1) expires on or before May 1, 2012.

Par. 23. Section 20.2055–2 is amended by revising the heading in paragraph (e)(3) and revising the text in paragraphs (e)(3)(iii) and (f)(4) to read as follows:

§20.2055–2 Transfers not exclusively for charitable purposes .

- - - (e) - -

May 18, 2009 1001 2009–20 I.R.B.

If the quotient obtained falls between two terms, the longer term is used.

(c)(5) through (c)(7). [Reserved]. For further guidance, see §20.2056A–4(c)(5) through (c)(7).

(d) Examples 1 through 3 . [Reserved]. For further guidance, see §20.2056A–4(d) Examples 1 through 3 .

Example 4 . Computation of corpus portion of an- nuity payment . (i) At the time of D’s death on or after May 1, 2009, D is a participant in an employees’ pension plan described in section 401(a). On D’s death, D’s spouse S, a resident of the United States, becomes entitled to receive a survivor’s annuity of $72,000 per year, payable monthly, for life. At the time of D’s death, S is age 60. Assume that under section 7520, the appropriate discount rate to be used for valuing annuities in the case of this decedent is 6.0 percent. The annuity factor at 6.0 percent for a person age 60 is 11.0625 (1.0000 minus .33625, divided by .06). The adjustment factor at 6.0 percent in Table K for monthly payments is 1.0272. Accordingly, the right to receive $72,000 per year on a monthly basis is equal to the right to receive $73,958.40 ($72,000 x 1.0272) on an annual basis. (ii) The corpus portion of each annuity payment received by S is determined as follows. The first step is to determine the annuity factor for the number of years that would be required to exhaust a hypothetical fund that has a present value and a payout corresponding to S ’s interest in the payments under the plan, determined as follows:

(A) Present value of S ’s annuity: $73,958.40 x 11.0625 = $818,164.80. (B) Annuity Factor for Expected Annuity Term: $818,164.80 / $73,958.40 = 11.0625

(iii) The second step is to determine the number of years that would be required for S ’s annuity to exhaust a hypothetical fund of $818,164.80. The term certain annuity factor of 11.0625 falls between the annuity factors for 18 and 19 years in a 6.0 percent term certain annuity table (Column 1 of Table B, Publication 1457, Actuarial Valuations Version 3A, which may be obtained on the IRS Internet site). Accordingly, the expected annuity term is 19 years.

(iv) The third step is to determine the corpus amount by dividing the expected term of 19 years into the present value of the hypothetical fund as follows:

Corpus amount of annual payment:

$818,164.80/19 = $43,061.31

(v) In the fourth step, the corpus portion of each annuity payment is determined by dividing the corpus amount of each annual payment by the annual annuity payment (adjusted for payments more frequently than annually as in (i) of this Example 4 ) as follows:

Corpus portion of each annuity payment:

$43,061.31/$73,958.40 = .58

(vi) Accordingly, 58 percent of each payment to S is deemed to be a distribution of corpus. A marital deduction is allowed for $818,164.80, the present value of the annuity as of D’s date of death, if either: S agrees to roll over the corpus portion of each payment to a QDOT and the executor files the Information Statement described in paragraph (c)(5) of this

taking the factor for valuing the annuity or unitrust interest for the named individual measuring life and identifying the term of years (rounded up to the next whole year) that corresponds to the equivalent term of years factor for an annuity or unitrust interest. For example, in the case of an annuity interest payable for the life of an individual age 40 at the time of the transfer on or after May 1, 2009, assuming an interest rate of 7.4 percent under section 7520, the annuity factor from column 1 of Table S(7.4), contained in IRS Publication 1457, Actuarial Valuations Version 3A, for the life of an individual age 40 is 12.1519 (1.00000 minus .10076, divided by .074). Based on Table B(7.4), contained in Publication 1457, Actuarial Valuations Version 3A, the factor 12.1519 corresponds to a term of years between 32 and 33 years. Accordingly, the annuity interest must be reformed into an interest payable for a term of 33 years. A judicial reformation must be commenced prior to the later of July 5, 2001, or the date prescribed by section 2055(e)(3)(C)(iii). Any judicial reformation must be completed within a reasonable time after it is commenced. A non-judicial reformation is permitted if effective under state law, provided it is completed by the date on which a judicial reformation must be commenced. In the alternative, if a court, in a proceeding that is commenced on or before July 5, 2001, declares any transfer made pursuant to a will or revocable trust where the decedent dies on or after April 4, 2000, and on or before March 6, 2001, null and void ab initio, the Internal Revenue Service will treat such transfers in a manner similar to that described in section 2055(e)(3)(J).

(e)(4) through (f)(3). [Reserved]. For further guidance, see §20.2055–2(e)(4) through (f)(3).

(f)(4) Other decedents . The present value of an interest not described in paragraph (f)(2) of this section is to be determined under §20.2031–7T(d) in the case of decedents where the valuation date of the gross estate is on or after May 1, 2009, or under §20.2031–7A in the case of decedents where the valuation date of the gross estate is before May 1, 2009.

(f)(5) [Reserved]. For further guidance, see §20.2055–2(f)(5).

(f)(6) Effective/applicability date . Paragraphs (e)(3)(iii) and (f)(4) apply on or after May 1, 2009.

(f)(7) Expiration date . Paragraphs (e)(3)(iii) and (f)(4) expire on or before May 1, 2012.

Par. 25. Section 20.2056A–4 is amended by revising paragraph (c)(4)(ii)(B) and Example 4 of paragraph (d). The revisions reads as follows:

§20.2056A–4 Procedures for conforming marital trusts and nontrust marital transfers to the requirements of a qualified domestic trust .

- - - (c) - - (4) - - (ii) - - * (B) [Reserved]. For further guidance, see §20.2056A–4T(c)(4)(ii)(B).

(d) - - Example 4 . [Reserved]. For further guidance, see §20.2056A–4T(d) Example 4 . Par. 26. Section 20.2056A–4T is added to read as follows:

§20.2056A–4T Procedures for conforming marital trusts and nontrust marital transfers to the requirements of a qualified domestic trust (temporary) .

(a) through (c)(4)(ii)(A). [Reserved]. For further guidance, see §20.2056A–4(a) through (c)(4)(ii)(A).

(c)(4)(ii)(B) The total present value of the annuity or other payment is the present value of the nonassignable annuity or other payment as of the date of the decedent’s death, determined in accordance with the interest rates and mortality data prescribed by section 7520. The expected annuity term is the number of years that would be required for the scheduled payments to exhaust a hypothetical fund equal to the present value of the scheduled payments. This is determined by first dividing the total present value of the payments by the annual payment. From the quotient so obtained, the expected annuity term is derived by identifying the term of years that corresponds to the annuity factor equal to the quotient. This is determined by using column 1 of Table B, for the applicable interest rate, contained in Publication 1457, Actuarial Valuations Version 3A. A copy of this publication is available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov .

2009–20 I.R.B. 1002 May 18, 2009

census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the revised mortality component tables will be published in the regulations at that time. For decedent’s estates with valuation dates on or after May 1, 2009, the mortality component table (Table 2000CM) is contained in §20.2031–7T(d)(7). See §20.2031–7A for mortality component tables applicable to decedent’s estates with valuation dates before May 1, 2009.

(1) Regulation sections containing ta- bles with interest rates between 0.2 and 14 percent for valuation dates on or after May 1, 2009 . Section 1.642(c)–6T(e)(6) contains Table S used for determining the present value of a single life remainder interest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for single life remainder factors applicable to valuation dates before May 1, 2009. Section 1.664–4(e)(6) contains Table F (payout factors) and Table D (actuarial factors used in determining the present value of a remainder interest postponed for a term of years). Section1.664–4T(e)(7) contains Table U(1) (unitrust single life remainder factors). These tables are used in determining the present value of a remainder interest in a charitable remainder unitrust as defined in §1.664–3. See §1.664–4A for unitrust single life remainder factors applicable to valuation dates before May 1, 2009. Section 20.2031–7(d)(6) contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), and Table J (term certain annuity beginningof-interval adjustment factors). Section 20.2031–7T(d)(7) contains Table S (single life remainder factors), and Table 2000CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A for single life remainder factors applicable to valuation dates before May 1, 2009.

section and the Roll Over Agreement described in paragraph (c)(7) of this section; or S agrees to pay the tax due on the corpus portion of each payment and the executor files the Information Statement described in paragraph (c)(5) of this section and the Payment Agreement described in paragraph (c)(6) of this section.

Example 5 . [Reserved]. For further guidance, see §20.2056A–4(d) Example 5 .

(e) Effective/applicability date . Paragraph (c)(4)(ii)(B) and Example 4 in paragraph (d) of this section are applicable with respect to decedents dying on or after May 1, 2009. (f) Expiration date . Paragraph (c)(4)(ii)(B) and Example 4 in paragraph (d) of this section expire on or before May 1, 2012. Par. 27. Section 20.7520–1 is amended by:

Revising the section heading.
Revising the second sentence of paragraph (a)(1) and revising paragraph (a)(2).
Removing the last two sentences of paragraph (b)(2) and adding a new sentence at the end of the paragraph.
Revising paragraphs (c)(1), (c)(2), and (d).

The revisions and additions read as follows:

§20.7520–1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests prior to May 1, 2009 .

- - - (a) - - *(1) - - - For periods prior to May 1, 2009, see §20.2031–7A for the computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) For a transfer to a pooled income fund prior to May 1, 2009, see §1.642(c)–6A (Income Tax Regulations) with respect to the valuation of the remainder interest.

- - - (b) - - (2) * * * For decedents’ estates with valuation dates after April 30, 1989, and before May 1, 2009, the mortality component tables are contained in §20.2031–7A.

(1) [Reserved]. For further guidance, see §20.7520–1T(c)(1).

- - - (d) Effective/applicability dates . This section applies after April 30, 1989, and before May 1, 2009.

Par. 28. Section 20.7520–1T is added to read as follows:

§20.7520–1T Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests on or after May 1, 2009 (temporary) .

(a) General actuarial valuations . (1) Except as otherwise provided in this section and in §20.7520–3 (relating to exceptions to the use of prescribed tables under certain circumstances), in the case of estates of decedents with valuation dates after April 30, 1989, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), remainders, and reversions is their present value determined under this section. See §20.2031–7T(d) (and, for certain prior periods, §20.2031–7A) for the computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) In the case of a transfer to a pooled income fund with a valuation date on or after May 1, 2009, see §1.642(c)–6T(e), Income Tax Regulations, (or, for certain prior periods, §1.642(c)–6A) with respect to the valuation of the remainder interest.

(3) [Reserved]. For further guidance, see §20.7520–1(a)(3).

(b)(1) [Reserved]. For further guidance, see §20.7520–1(b)(1).

(2) Mortality component . The mortality component reflects the mortality data most recently available from the United States

May 18, 2009 1003 2009–20 I.R.B.

of years, and remainder or reversionary interests transferred before May 1, 2009.

Par. 31. Section 25.2512–5 is amended by revising paragraphs (c), (d), and (e) to read as follows:

The revised provisions read as follows:

§25.2512–5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests .

- - - (c) and (d) [Reserved]. For further guidance, see §25.2512–5T(c) and (d).

(e) Effective/applicability dates . This section applies after April 30, 1999, and before May 1, 2009.

Par. 32. Section 25.2512–5T is added to read as follows:

§25.2512–5T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary) .

(a) and (b) [Reserved]. For further guidance, see §25.2512–5(a) and (b).

(c) Actuarial valuations . The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift on or after May 1, 2009, is determined under paragraph (d) of this section. The present value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift before May 1, 2009, is determined under the following sections:

May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov :

(d) Effective/applicability date . This section applies on or after May 1, 2009.

(e) Expiration date . This section expires on or before May 1, 2012.

PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954

Par. 29. The authority citation for part 25 is amended by adding entries in numerical order to read in part as follows:

Authority: 26 U.S.C. 7805 * * * Section 25.2512–5T also issued under 26 U.S.C. 7520(c)(2). Section 25.7520–1T also issued under 26 U.S.C. 7520(c)(2). - * * Par. 30. Section 25.2512–0 is revised to read as follows:

§25.2512–0 Table of contents .

This section lists the section headings that appear in the regulations under section 2512. §25.2512–1 Valuation of property; in general.

§25.2512–2 Stocks and bonds. §25.2512–3 Valuation of interests in businesses.

§25.2512–4 Valuation of notes. §25.2512–5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.

§25.2512–5T Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests (temporary).

§25.2512–6 Valuation of certain life insurance and annuity contracts; valuation of shares in an open-end investment company.

§25.2512–7 Effect of excise tax. §25.2512–8 Transfers for insufficient consideration.

Actuarial Tables Applicable Before

May 1, 2009

§25.2512–5A Valuation of annuities, unitrust interests, interests for life or term

Transfers

After Before

Applicable Regulations

01–01–52 25.2512–5A(a) 12–31–51 01–01–71 25.2512–5A(b) 12–31–70 12–01–83 25.2512–5A(c) 11–30–83 05–01–89 25.2512–5A(d) 04–30–89 05–01–99 25.2512–5A(e) 04–30–99 05–01–09 25.2512–5A(f)

ble, the mortality component for the valuation date of the interest that is being valued. See §§25.7520–1 through 25.7520–4. The fair market value of a qualified annuity interest described in section 2702(b)(1) and a qualified unitrust interest described in section 2702(b)(2) is the present value of such interests determined under §25.7520–1(c).

(d) Actuarial valuations on or after May 1, 2009 —(1) In general . Except as otherwise provided in paragraph (b) of this section and §25.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances), if the valuation date for the gift is on or after May 1, 2009, the fair market value of annuities,

life estates, terms of years, remainders, and reversions transferred on or after May 1, 2009, is the present value of such interests determined under paragraph (d)(2) of this section and by use of standard or special section 7520 actuarial factors. These factors are derived by using the appropriate section 7520 interest rate and, if applica

2009–20 I.R.B. 1004 May 18, 2009

for a term of years) and in Table S (for a remainder interest after an annuity payable for the life of one individual when the valuation date is on or after May 1, 2009). However, annuity actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in §20.2031–7T(d)(7) (or in §20.2031–7A). If Internal Revenue Service Publication 1457 (or any other reliable source of annuity actuarial factors) is not conveniently available, an annuity factor for a term of years or for one life may be derived mathematically. This annuity factor may be derived by subtracting the applicable remainder factor (that corresponds to the applicable section 7520 interest rate and annuity period) in Table B (in the case of a term-of-years annuity) in §20.2031–7(d)(6) or in Table S (in the case of a one-life annuity) in §20.2031–7T(d)(7), as the case may be, from 1.000000 and then dividing the result by the applicable section 7520 interest rate expressed as a decimal number. See §20.2031–7T(d)(2)(iv) for an example that illustrates the computation of the present value of an annuity.

(B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods, the product obtained by multiplying the annuity factor by the aggregate amount payable annually is then multiplied by the applicable adjustment factor set forth in Table K in §20.2031–7(d)(6) at the appropriate interest rate component for payments made at the end of the specified periods. The provisions of this paragraph (d)(2)(iv)(B) are illustrated by the following example:

Example . In July of a year after 2008, the donor agreed to pay the annuitant the sum of $10,000 per year, payable in equal semiannual installments at the end of each period. The semiannual installments are to be made on each December 31st and June 30th. The annuity is payable until the annuitant’s death. On the date of the agreement, the annuitant is 68 years and 5 months old. The donee annuitant’s age is treated as 68 for purposes of computing the present value of the annuity. The section 7520 rate on the date of the agreement is 6.6 percent. Under Table S in §20.2031–7T(d)(7), the factor at 6.6 percent for determining the present value of a remainder interest payable at the death of an individual aged 68 is .42001. Converting the remainder factor to an annuity factor, as described above, the annuity factor for determining the present value of an annuity transferred to an individual age 68 is 8.7877 (1.00000 minus .42001 divided by .066). The adjustment factor from Table K in §20.2031–7(d)(6) in the column for payments made at the end of each semiannual period at the rate of 6.6 percent is 1.0162. The aggregate

(2) Specific interests . When the donor transfers property in trust or otherwise and retains an interest therein, generally, the value of the gift is the value of the property transferred less the value of the donor’s retained interest. However, if the donor transfers property after October 8, 1990, to or for the benefit of a member of the donor’s family, the value of the gift is the value of the property transferred less the value of the donor’s retained interest as determined under section 2702. If the donor assigns or relinquishes an annuity, life estate, remainder, or reversion that the donor holds by virtue of a transfer previously made by the donor or another, the value of the gift is the value of the interest transferred. However, see section 2519 for a special rule in the case of the assignment of an income interest by a person who received the interest from a spouse.

(i) Charitable remainder trusts . The fair market value of a remainder interest in a pooled income fund, as defined in §1.642(c)–5, is its value determined under §1.642(c)–6T(e) (see §1.642(c)–6A for certain prior periods). The fair market value of a remainder interest in a charitable remainder annuity trust, as described in §1.664–2(a), is its present value determined under §1.664–2(c). The fair market value of a remainder interest in a charitable remainder unitrust, as defined in §1.664–3, is its present value determined under §1.664–4T(e). The fair market value of a life interest or term for years in a charitable remainder unitrust is the fair market value of the property as of the date of transfer less the fair market value of the remainder interest, determined under §1.664–4T(e)(4) and (5).

Revenue Service Publication 1457. See §20.2031–7A containing Table S for valuation of interests before May 1, 2009. For information about obtaining actuarial factors for other types of remainder interests, see paragraph (d)(4) of this section.

(iii) Ordinary term-of-years and life in- terests . If the interest to be valued is the right of a person to receive the income of certain property, or to use certain nonincome-producing property, for a term of years or for the life of one individual, the present value of the interest is computed by multiplying the value of the property by the appropriate term-of-years or life interest actuarial factor (that corresponds to the applicable section 7520 interest rate and term-of-years or life interest period). Internal Revenue Service Publication 1457 includes actuarial factors for a remainder interest after a term of years in Table B and after the life of one individual in Table S (for one measuring life when the valuation date is on or after May 1, 2009). However, term-of-years and life interest actuarial factors are not included in Table B in §20.2031–7(d)(6) or Table S in §20.2031–7T(d)(7) (or in §20.2031–7A). If Internal Revenue Service Publication 1457 (or any other reliable source of term-of-years and life interest actuarial factors) is not conveniently available, an actuarial factor for the interest may be derived mathematically. This actuarial factor may be derived by subtracting the correlative remainder factor (that corresponds to the applicable section 7520 interest rate) in Table B (for a term of years) in §20.2031–7(d)(6) or in Table S (for the life of one individual) in §20.2031–7T(d)(7), as the case may be, from 1.000000. For information about obtaining actuarial factors for other types of term-of-years and life interests, see paragraph (d)(4) of this section.

May 18, 2009 1005 2009–20 I.R.B.

annual amount of the annuity, $10,000, is multiplied by the factor 8.7877 and the product is multiplied by 1.0162. The present value of the donee’s annuity is, therefore, $89,300.61 ($10,000 X 8.7877 X 1.0162).

(C) If an annuity is payable at the beginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is computed by multiplying the aggregate amount payable annually by the annuity factor described in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Table J in §20.2031–7(d)(6) at the appropriate interest rate component for payments made at the beginning of specified periods. If an annuity is payable at the beginning of

annual, semiannual, quarterly, monthly, or weekly periods for one or more lives, the value of the annuity is the sum of the first payment and the present value of a similar annuity, the first payment of which is not to be made until the end of the payment period, determined as provided in paragraph (d)(2)(iv)(B) of this section.

(v) Annuity and unitrust interests for a term of years or until the prior death of an individual —(A) Annuity interests . The present value of an annuity interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in

TABLE S value at 5.8 percent, age 60 . . . . . . .34656 TABLE S value at 5.8 percent, age 70 . . . . . . .49025 TABLE 2000CM value at age 70 . . . . . . . . . . 74794 TABLE 2000CM value at age 60 . . . . . . . . . . 87595 TABLE B value at 5.8 percent, 10 years . . . . . .569041 TABLE K value at 5.8 percent . . . . . . . . . . . . 1.0143

Factor for donor’s retained interest at 5.8 percent:

(1.00000 - .34656) - (.569041 X (74794/87595) X (1.00000 - .49025)) = 6.9959

.058

Present value of donor’s retained interest:

($6,000 X 6.9959 X 1.0143) $42,575.65

§§20.2031–7(d)(6) and 20.2031–7T(d)(7) as described in the following example:

Example . The donor transfers $100,000 into a trust on or after May 1, 2009, and retains the right to receive an annuity from the trust in the amount of $6,000 per year, payable in equal semiannual installments at the end of each period. The semiannual installments are to be made on each June 30th and December 31st. The annuity is payable for 10 years or until the donor’s prior death. At the time of the transfer, the donor is 59 years and 6 months old. The donor’s age is deemed to be 60 for purposes of computing the present value of the retained annuity. The section 7520 rate for the month in which the transfer occurred is 5.8 percent. The present value of the donor’s retained interest is $42,575.65, determined as follows:

for 10 years or until the prior death of the donor. The section 7520 rate for the January in which the transfer occurred is 6.6 percent. Under Table F(6.6) in §1.664–4(e)(6), the appropriate adjustment factor is .953317 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 5.720 percent (6% X .953317). The present value of the donor’s retained interest is $41,920.00 determined as follows:

(B) Unitrust interests . The present value of a unitrust interest that is payable until the earlier to occur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in §§1.664–4(e)(6)

and 1.664–4T(e)(7) as described in the following example:

Example . The donor who, as of the nearest birthday, is 60 years old, transfers $100,000 to a unitrust on January 1 ^st of a year after 2009. The trust instrument requires that each year the trust pay to the donor, in equal semiannual installments on June 30th and December 31st, 6 percent of the fair market value of the trust assets, valued as of January 1st each year,

TABLE U(1) value at 5.6 percent, age 60 . . . . . . . . . . . . . . .33970 TABLE U(1) value at 5.6 percent, age 70 . . . . . . . . . . . . . . .48352 TABLE 2000CM value at age 70 . . . . . . . . . . . . . . . . . . . . 74794 TABLE 2000CM value at age 60 . . . . . . . . . . . . . . . . . . . . 87595 TABLE D value at 5.6 percent, 10 years . . . . . . . . . . . . . . . .561979

Factor for donor’s retained interest at 5.6 percent:

(1.000000 - .33970) - (.561979 X (74794/87595) X (1.000000 - .48352)) = .41247

TABLE U(1) value at 5.8 percent, age 60 . . . . . . . . . . . . . . .32846 TABLE U(1) value at 5.8 percent, age 70 . . . . . . . . . . . . . . .47241 TABLE 2000CM value at age 70 . . . . . . . . . . . . . . . . . . . . 74794 TABLE 2000CM value at age 60 . . . . . . . . . . . . . . . . . . . . 87595 TABLE D value at 5.8 percent, 10 years . . . . . . . . . . . . . . . .550185

Factor for donor’s retained interest at 5.8 percent:

(1.000000 - .32846) - (.550185 X (74974/87595) X (1.000000 - .47241)) = .42369

Difference. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .01122

2009–20 I.R.B. 1006 May 18, 2009

Interpolation adjustment:

5.720% - 5.6% = x 0.2% .01122 x = .00673

Factor at 5.6 percent, age 60 . . . . . . . . . . . . . . . . . . . . . . . . .41247 Plus: Interpolation adjustment . . . . . . . . . . . . . . . . . . . . . . .00673 Interpolated Factor . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .41920

Present value of donor’s retained interest:

($100,000 X .41920) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $41,920.00

life, and remainder interests in property. These sections also refer to standard and special actuarial factors that may be necessary to compute the present value of similar interests in more unusual fact situations. These factors and examples are also generally applicable for gift tax purposes in computing the values of taxable gifts.

(2) Transitional rule . If the valuation date of a transfer of property by gift is after April 30, 1999, and before July 1, 1999, the fair market value of the interest transferred is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§25.7520–1(b) and 25.7520–2(a)(2)) and the appropriate actuarial tables under either §20.2031–7A(e)(4) or §20.2031–7A(f)(4), at the option of the donor. However, with respect to each individual transaction and with respect to all transfers occurring on the valuation date, the donor must use the same actuarial tables (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all transfers made on the same date must be valued based on the same tables).

(3) Publications and actuarial com- putations by the Internal Revenue Ser- vice . Many standard actuarial factors not included in §§20.2031–7(d)(6) and 20.2031–7A(f)(4) are included in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (7–99). Internal Revenue Service Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office. However, pertinent factors in this publication may be obtained from: CC:PA:LPD:PR (IRS Publication 1457), Room 5205, Internal

(3) Transitional rule . If the valuation date of a transfer of property by gift is on or after May 1, 2009, and before July 1, 2009, the fair market value of the interest transferred is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (see §§25.7520–1(b) and 25.7520–2(a)(2)) and the appropriate actuarial tables under either §20.2031–7T(d)(7) or §20.2031–7A(f)(4), at the option of the donor. However, with respect to each individual transaction and with respect to all transfers occurring on the valuation date, the donor must use the same actuarial tables (for example, gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all transfers made on the same date must be valued based on the same tables).

(4) Publications and actuarial com- putations by the Internal Revenue Ser- vice . Many standard actuarial factors not included in §20.2031–7(d)(6) or §20.2031–7T(d)(7) are included in Internal Revenue Service Publication 1457, “Actuarial Valuations Version 3A” (2009). Internal Revenue Service Publication 1457 also includes examples that illustrate how to compute many special factors for more unusual situations. A copy of this publication is available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov . If a special factor is required in the case of a completed gift, the Internal Revenue Service may furnish the factor to the donor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the gift, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodi

cally in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)( b )) and include payment of the required user fee.

(e) Effective/applicability date . This section applies on or after May 1, 2009.

(f) Expiration date . This section expires on or before May 1, 2012.

Par. 33. The undesignated center heading immediately preceding §25.2512–5A is revised to read as follows:

Actuarial Tables Applicable Before May 1, 2009

Par. 34. Section 25.2512–5A is amended by revising the section heading and adding paragraph (f) to read as follows:

§25.2512–5A Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests transferred before May 1, 2009 .

- - - (f) Valuation of annuities, unitrust in- terests, interests for life or term of years, and remainder or reversionary interests transferred after April 30, 1999, and be- fore May 1, 2009 —(1) In general . Except as otherwise provided in §§25.2512–5(b) and 25.7520–3(b) (pertaining to certain limitations on the use of prescribed tables), if the valuation date of the transferred interest is after April 30, 1999, and before May 1, 2009, the fair market value of annuities, unitrust interests, life estates, terms of years, remainders, and reversions transferred by gift is the present value of the interests determined by use of standard or special section 7520 actuarial factors and the valuation methodology described in §25.2512–5T(d). Sections 20.2031–7(d)(6) and 20.2031–7A(f)(4) and related sections provide tables with standard actuarial factors and examples that illustrate how to use the tables to compute the present value of ordinary annuity,

May 18, 2009 1007 2009–20 I.R.B.

(a) - - *(1) - - - For periods prior to May 1, 2009, see §20.2031–7A for the computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) For a gift to a pooled income fund prior to May 1, 2009, see §1.642(c)–6A (Income Tax Regulations) with respect to the valuation of the remainder interest.

- - - (b) - * (2) * * * For transactions with valuation dates after April 30, 1989, and before May 1, 2009, the mortality component tables are contained in §20.2031–7A.

- - - (d) Effective/applicability dates . This section applies after April 30, 1989, and before May 1, 2009.

Par. 38. Section 25.7520–1T is added to read as follows:

§25.7520–1T Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests on or after May 1, 2009 (temporary) .

(a) General actuarial valuations . (1) Except as otherwise provided in this section and in §25.7520–3 (relating to exceptions to the use of prescribed tables under certain circumstances), in the case of certain gifts after April 30, 1989, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), remainders, and reversions is their present value determined under this section. See §20.2031–7T(d) (and, for certain prior periods, §20.2031–7A) for the

Revenue Service, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044. If a special factor is required in the case of a completed gift, the Internal Revenue Service may furnish the factor to the donor upon a request for a ruling. The request for a ruling must be accompanied by a recitation of the facts including a statement of the date of birth for each measuring life, the date of the gift, any other applicable dates, and a copy of the will, trust, or other relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (see §§601.201 and 601.601(d)(2)(ii)( b )) and include payment of the required user fee.

(4) Effective/applicability dates . Paragraphs (f)(1) through (f)(3) apply after April 30, 1999, and before May 1, 2009.

Par. 35. Section 25.2522(c)–3 is amended by revising paragraph (e) to read as follows:

§25.2522(c)–3 Transfers not exclusively for charitable, etc., purposes in the case of gifts made after July 31, 1969 .

- - - (e) [Reserved]. For further guidance, see §25.2522(c)–3T(e).

Par. 36. Section 25.2522(c)–3T is added as follows:

§25.2522(c)–3T Transfers not exclusively for charitable, etc., purposes in the case of gifts made after July 31, 1969 (temporary) .

(a) through (d) [Reserved]. For further guidance, see §25.2522(c)–3(a) through (d).

(e) Effective/applicability date . This section applies only to gifts made after July 31, 1969. In addition, the rule in paragraphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this section that guaranteed annuity interests or unitrust interests, respectively, may be payable for a specified term of years or for the life or lives of only certain individuals applies to transfers made on or after April 4, 2000. If a transfer is made on or after April 4, 2000, that uses an individual other than one permitted in paragraphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this section, the interest may be reformed into a lead interest payable for a specified term of years. The term of years is determined by taking the factor for valuing the annuity or

unitrust interest for the named individual measuring life and identifying the term of years (rounded up to the next whole year) that corresponds to the equivalent term of years factor for an annuity or unitrust interest. For example, in the case of an annuity interest payable for the life of an individual age 40 at the time of the transfer on or after May 1, 2009, assuming an interest rate of 7.4 percent under section 7520, the annuity factor from column 1 of Table S(7.4), contained in IRS Publication 1457, Actu- arial Valuations Version 3A, for the life of an individual age 40 is 12.1519 (1 - .10076 / .074). Based on Table B(7.4), contained in Publication 1457, Actuarial Valuations Version 3A, the factor 12.1519 corresponds to a term of years between 32 and 33 years. Accordingly, the annuity interest must be reformed into an interest payable for a term of 33 years. A judicial reformation must be commenced prior to October 15th of the year following the year in which the transfer is made and must be completed within a reasonable time after it is commenced. A non-judicial reformation is permitted if effective under state law, provided it is completed by the date on which a judicial reformation must be commenced. In the alternative, if a court, in a proceeding that is commenced on or before July 5, 2001, declares any transfer, made on or after April 4, 2000, and on or before March 6, 2001, null and void ab initio, the Internal Revenue Service will treat such transfers in a manner similar to that described in section 2055(e)(3)(J). Par. 37. Section 25.7520–1 is amended by:

Revising the section heading.
Revising the second sentence of paragraph (a)(1) and revising paragraph (a)(2).
Removing the last two sentences of paragraph (b)(2) and adding a new sentence at the end.
Revising paragraphs (c)(1), (c)(2), and (d).

The revisions and additions read as follows:

§25.7520–1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests prior to May 1, 2009 .

2009–20 I.R.B. 1008 May 18, 2009

(d) Effective/applicability date . This section applies on or after May 1, 2009.

(e) Expiration date . This section expires on or before May 1, 2012.

Par. 39. Section 25.7520–3 is amended by revising paragraph (b)(2)(v), Example 5 and paragraph (b)(4) to read as follows:

§25.7520–3 Limitation on the application of section 7520 .

- - - (b) - * (2) - * (v) - * Example 5 . [Reserved]. For further guidance, see §25.7520–3T(b)(2)(v) Ex- ample 5 .
- - - (4) [Reserved]. For further guidance, see §25.7520–3T(b)(4).
- - - Par. 40. Section 25.7520–3T is added as follows:

§25.7520–3T Limitation on the application of section 7520 (temporary) .

(a) through (b)(2)(iv) [Reserved]. For further guidance, see §25.7520–3(a) through (b)(2)(iv).

(b)(2)(v) Examples 1 through 4 .

[Reserved]. For further guidance, see §25.7520–3(b)(2)(v) Examples 1 through 4 . Example 5 . Eroding corpus in an annuity trust . (i) The donor, who is age 60 and in normal health, transfers property worth $1,000,000 to a trust on or after May 1, 2009. The trust will pay a 10 percent ($100,000 per year) annuity to a charitable organization for the life of the donor, payable annually at the end of each period, and the remainder then will be distributed to the donor’s child. The section 7520 rate for the month of the transfer is 6.8 percent. First, it is necessary to determine whether the annuity may exhaust the corpus before all annuity payments are made. Because it is assumed that any measuring life may survive until age 110, any life annuity could require payments until the measuring life reaches age 110. Based on a section 7520 interest rate of 6.8 percent, the determination of whether the annuity may exhaust the corpus before the annuity payments are made is computed as follows:

computation of the value of annuities, unitrust interests, life estates, terms for years, remainders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section.

(2) In the case of a gift to a beneficiary of a pooled income fund on or after May 1, 2009, see §1.642(c)–6T(e) (or, for certain prior periods, §1.642(c)–6A) with respect to the valuation of the remainder interest.

(3) [Reserved]. For further guidance, see §25.7520–1(a)(3).

(b)(1) [Reserved]. For further guidance, see §25.7520–1(b)(1).

(2) Mortality component . The mortality component reflects the mortality data most recently available from the United States census. As new mortality data becomes available after each decennial census, the mortality component described in this section will be revised periodically and the revised mortality component tables will be published in the regulations at that time. For gifts with valuation dates on or after May 1, 2009, the mortality component table (Table 2000CM) is contained in §20.2031–7T(d)(7). See §20.2031–7A for mortality component tables applicable to gifts for which the valuation date falls before May 1, 2009.

for unitrust single life remainder factors applicable to valuation dates before May 1, 2009. Section 20.2031–7(d)(6) contains Table B (actuarial factors used in determining the present value of an interest for a term of years), Table K (annuity end-of-interval adjustment factors), and Table J (term certain annuity beginningof-interval adjustment factors). Section 20.2031–7T(d)(7) contains Table S (single life remainder factors), and Table 2000CM (mortality components). These tables are used in determining the present value of annuities, life estates, remainders, and reversions. See §20.2031–7A for single life remainder factors and mortality components applicable to valuation dates before May 1, 2009.

(2) Internal Revenue Service publica- tions containing tables with interest rates between 0.2 and 22 percent for valuation dates on or after May 1, 2009. The following documents are available beginning May 1, 2009, at no charge, electronically via the IRS Internet site at www.irs.gov :

May 18, 2009 1009 2009–20 I.R.B.

Age to which life annuity may continue . . . . . . . . . . . . . . . . . . 110 less: Age of measuring life at date of transfer . . . . . . . . . . . . . . 60 Number of years annuity may continue . . . . . . . . . . . . . . . . 50

Annual annuity payment . . . . . . . . . . . . . . . . . . . . . . . . . . . $100,000.00 times: Annuity factor for 50 years

derived from Table B (1 - .037277 / .068). . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14.1577 Present value of term certain annuity. . . . . . . . . . . . . . . . . . . . . $1,415,770.00

(ii) Because the present value of an annuity for a term of 50 years exceeds the corpus, the annuity may exhaust the trust before all payments are made. Consequently, the annuity must be valued as an annuity payable for a term of years or until the prior death of the annuitant, with the term of years determined by when the fund will be exhausted by the annuity payments.

(iii) The annuity factor for a term of years at 6.8 percent is derived by subtracting the applicable remainder factor in Table B (see §20.2031–7(d)(6)) from 1.000000 and then dividing the result by .068. An annuity of $100,000 payable at the end of each year for a period that has an annuity factor of 10.0 would have a present value exactly equal to the principal available to pay the annuity over the term. The annuity factor for 17 years is 9.8999 and the annuity factor for 18 years is 10.2059. Thus, it is determined that the $1,000,000 initial transfer will be sufficient to make 17 annual payments of $100,000, but not to make the entire 18th payment. The present value of an annuity of $100,000 payable at the end of each year for 17 years certain is $100,000 times 9.8999 or $989,990. The remaining amount is $10,010.00. Of the initial corpus amount, $10,010.00 is not needed to make payments for 17 years, so this amount, as accumulated for 18 years, will be available for the final payment. The 18-year accumulation factor is (1 + 0.068) ¹⁸ or 3.268004. Then the amount available in 18 years is $10,010.00 times 3.268004 or $32,712.72. Therefore, for purposes of analysis we consider the annuity payments as being composed of two distinct annuity components. The two annuity components taken together must equal the total annual amount of $100,000. The first annuity is the

exact amount that the trust will have available for the final payment, $32,712.72. The second annuity component then must be $100,000 minus $32,712.72, or $67,287.28. Specifically, the initial corpus will be able to make payments of $67,287.28 per year for 17 years plus payments of $32,712.72 per year for 18 years. The total annuity is valued by adding the value of the two separate temporary component annuities.

(iv) Based on Table H of Publication 1457, Actuarial Valuations Version 3A, which may be obtained from the IRS Internet site, the present value of an annuity of $67,287.28 per year payable for 17 years or until the prior death of a person aged 60 is $597,013.12 ($67,287.28 X 8.8726). The present value of an annuity of $32,712.72 per year payable for 18 years or until the prior death of a person aged 60 is $296,887.56 ($32,712.72 X 9.0756). Thus, the present value of the charitable annuity interest is $893,900.68 ($597,013.12 + $296,887.56).

(3) [Reserved]. For further guidance, see §25.7520–3(b)(3).

(4) Example . The provisions of paragraph (b)(3) of this section are illustrated by the following example:

Example . Terminal illness . The donor transfers property worth $1,000,000 to a child on or after May 1, 2009, in exchange for the child’s promise to pay the donor $80,000 per year for the donor’s life, payable annually at the end of each period. The donor is age 75 but has been diagnosed with an incurable illness and has at least a 50 percent probability of dying within 1 year. The section 7520 interest rate for the month of the transfer is 7.6 percent, and the standard annuity factor at that interest rate for a person

age 75 in normal health is 6.6493 (1 - .49465 / .076). Thus, if the donor were not terminally ill, the present value of the annuity would be $531,944.00 ($80,000 X 6.6493). Assuming the presumption provided in paragraph (b)(3) of this section does not apply, because there is at least a 50 percent probability that the donor will die within 1 year, the standard section 7520 annuity factor may not be used to determine the present value of the donor’s annuity interest. Instead, a special section 7520 annuity factor must be computed that takes into account the projection of the donor’s actual life expectancy.

(5) [Reserved]. For further guidance, see §25.7520–3(b)(5).

(c) Effective/applicability dates . Section 25.7520–3(a) is effective as of May 1, 1989. The provisions of paragraph (b) of this section, except Example 5 in paragraph (b)(2)(v) and paragraph (b)(4), are effective with respect to gifts made after December 13, 1995. Example 5 in paragraph (b)(2)(v) and paragraph (b)(4) are effective with respect to gifts made on or after May 1, 2009.

Par. 41. For each section listed in the table below, remove the language in the “Remove” column and add in its place the language in the “Add” column as set forth below:

Linda E. Stiff, Deputy Commissioner for Services and Enforcement.

Approved April 23, 2009.

Bernard J. Knight, Jr,

Acting General Counsel of the Treasury.

(Filed by the Office of the Federal Register on May 1, 2009, 4:15 p.m., and published in the issue of the Federal Register for May 7, 2009, 74 F.R. 21437)

2009–20 I.R.B. 1010 May 18, 2009