us-irs-revenue-procedures-irb-2009-20-pdf•Internal Revenue Bulletin 2009-20 (PDF rendition): IRS Revenue Procedures
Internal Revenue Bulletin 2009-20 (PDF rendition): IRS Revenue Procedures
us-irs-revenue-procedures-irb-2009-20-pdfInternal Revenue Bulletin 2009-20 (PDF rendition): IRS Revenue ProceduresGuidance
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Bulletin No. 200 9-20 May 18, 2009 HIGHLIGHTS OF THIS ISSUE These synopses are intended only as aids to the reader in identifying the subject matter covered. They may not be relied upon as authoritative interpretations. INCOME TAX T.D. 9448, page 942. REG–107845–08, page 1014. Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation ofinter vivosand testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available. Rev. Proc. 2009–28, page 1011. Self-determination of deficiency dividend under section 860(e)(4).This document provides procedures for regulated investment company (RIC) and real estate investment trust (REIT) self-determinations under section 860(e)(4) of the Code for purposes of the deficiency dividends procedures of section 860. EMPLOYEE PLANS Notice 2009–42, page 1011. Extension of date for multiemployer plans to elect re- lief under sections 204 and 205 of WRERA.This notice provides guidance to multiemployer plans making elections de- scribed in sections 204 and 205 of the Worker, Retiree, and Employer Recovery Act of 2008, P.L. 110–458 (WRERA). This notice also extends the time period for making elections de- scribed in section 204. This notice hereby substitutes “June 30, 2009,” for “April 30, 2009” in the paragraph above and wherever else it appears in Notice 2009–31. Notice 2009–31 modified. EXEMPT ORGANIZATIONS Announcement 2009–41, page 1026. The IRS has revoked its determination that the Michael and Laura Gallop Family Foundation of Agoura Hills, CA; Physician Directed Care of Southfield, MI; Winston County Community Development Corporation of Louisville, MS; EMF Debt Man- agement, Inc., of Pittsburgh, PA; Lil Pals & Gals Daycare Center Association of Tulsa, OK; Heartland Women’s Foun- dation, Inc., of Tribune, KS; CF Moore Charitable Foundation of Chicago, IL; Waimano Auxiliary, a/k/a Kokua Mau Work Center, of Ewa Beach, HI; The American Dream of West Jordan, UT; Henry Jacobson Family Foundation of Ross, CA; Dreamkeepers of America, Inc., of Memphis, TN; Community Workshop on Economic Development of Pueblo, CO; Hope Alive, Inc., of Pueblo, CO; Building Successful Lifestyles, Inc., of Topeka, KS; Hummingbird Tribal Foundation of Woodside, CA; Diamond-A-CAT-A-ME, Inc., of Houston, TX; Constitutional Educational Research Foundation of Rancho Cordova, CA; and Family Home Providers, Inc., of Cumming, GA, qualify as organizations described in sections 501(c)(3) and 170(c)(2) of the Code. (Continued on the next page) Finding Lists begin on page ii. ESTATE TAX T.D. 9448, page 942. REG–107845–08, page 1014. Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation ofinter vivosand testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available. REG–119532–08, page 1017. Proposed regulations under section 2036 of the Code pro- vide guidance on the portion of trust property includible in the grantor’s gross estate if the grantor has retained the use of the property, the right to an annuity, unitrust, graduated retained in- terest,orotherpaymentfromsuchpropertyforlife,foranype- riod not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death. GIFT TAX T.D. 9448, page 942. REG–107845–08, page 1014. Final, temporary, and proposed regulations under section 7520 of the Code provide guidance relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. The regulations will affect the valuation ofinter vivosand testamentary transfers of interests dependent on one or more measuring lives. The regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available. ADMINISTRATIVE Announcement 2009–39, page 1022. This document contains corrections to final and temporary reg- ulations (T.D. 9441, 2009–7 I.R.B. 460) providing further guid- ance and clarification regarding methods under section 482 of the Code to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in administering the current regulations. Announcement 2009–40, page 1023. This document contain corrections to proposed regulations (REG–143686–07, 2009–8 I.R.B. 579) providing guidance re- garding the recovery of stock basis in distributions under sec- tion 301 and transactions that are treated as dividends to which section 301 applies, as well as guidance regarding the deter- mination of gain and the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions. Announcement 2009–42, page 1027. This document contains corrections to final regulations (T.D. 9394, 2008–21 I.R.B. 988) regarding when a partnership may consider certain deductions and losses of a foreign partner to reduce or eliminate the partnership’s obligation to pay withhold- ing tax under section 1446 on effectively connected taxable income allocable under section 704 to such partner. May 18, 20092009–20 I.R.B. The IRS Mission Provide Americ a’s taxpayers top quality service by helping them understand an d meet their tax responsibilities and by applying the tax law with integrity and fairness to all. Introduction The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official rulings and procedures of the Internal Revenue Service and for publishing Treasury Decisions, Executive Orders, Tax Conven- tions, legislation, court decisions, and other items of general interest. It is published weekly and may be obtained from the Superintendent of Documents on a subscription basis. Bulletin contents are compiled semiannually into Cumulative Bulletins, which are sold on a single-copy basis. It is the policy of the Service to publish in the Bulletin all sub- stantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, mod- ify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indi- cated. Procedures relating solely to matters of internal man- agement are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. In those based on positions taken in rulings to taxpayers or technical advice to Service field offices, identifying details and information of a confidential nature are deleted to prevent unwarranted invasions of privacy and to comply with statutory requirements. Rulings and procedures reported in the Bulletin do not have the force and effect of Treasury Department Regulations, but they may be used as precedents. Unpublished rulings will not be relied on, used, or cited as precedents by Service personnel in the disposition of other cases. In applying published rulings and procedures, the effect of subsequent legislation, regulations, court decisions, rulings, and procedures must be considered, and Service personnel and others concerned are cautioned against reaching the same conclusions in other cases unless the facts and circumstances are substantially the same. The Bulletin is divided into four parts as follows: Part I.—19 86 Code. This part i ncludes rulings and decisions based on provisions of the Intern al Revenue Code of 1986. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions and Other Related Items, and Subpart B, Leg- islation and Related Committee Reports. Part III.—Administrative, Procedural, and Miscellaneous. To the extent practicable, pertinent cross references to these subjects are contained in the other Parts and Subparts. Also included in this part are Bank Secrecy Act Administrative Rul- ings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secre- tary (Enforcement). Part IV .—Items of General Interest. This par t includes notices of proposed rulemakings, disbar- ment an d suspension lists, and announcements. The last Bulletin for each month includes a cumulative index for the matters published during the preceding months. These monthly indexes are cumulated on a semiannual basis, and are published in the last Bulletin of each semiannual period. The c ontents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate. For sale by the Superintendent of Documents, U.S.Government Printing Office, Washington, DC 20402. 2009–20 I.R.B.May 18, 2009 May 18, 20092009–20 I.R.B. Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 7520. —Valuation Tables 26 CFR 1.7520– 1: Valuation of annuities unitrust in- terests, inte rests for life or terms of years, and remain- der or reversi onary interests prior to May 1, 2009. T.D. 9448 DEPARTMENT OF THE TREASURY Internal Rev enue Service 26 CFR Parts 1, 20, and 25 Use of Actua rial Tables in Valuing Ann uities, Interests for Life or Terms of Years, and Remainder or Reversionary Interest s AGENCY: I nternal Revenue Service (IRS), Tr easury. ACTION: F inal and temporary regula- tions. SUMMARY: This document contains reg- ulations relating to the use of actuarial tables i n valuing annuities, interests for life or t erms of years, and remainder or reversi onary interests. These regulations will aff ect the valuation ofinter vivos and test amentary transfers of interests de- penden t on one or more measuring lives. These r egulations are necessary because sectio n 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most re cent mortality experience avail- able. The text of the temporary regulations also s erves as the text of the proposed regul ations (REG–107845–08) set forth in the notice of proposed rulemaking on this s ubject elsewhere in this issue of the Bull etin. DATES:Effect ive Date:These regulations are effective on May 1, 2009. Applicabilit yDate:These regulations applyonMay1, 2009. FOR FURTHER I NFORMATION CONTACT: May er R. Samuels, (202) 622–3090 (no t a toll-free number). SUPPLEMENTA RY INFORMATION: Background This docume nt contains amendments to the regul ations revising certain tables used for the valuation of partial interests in propert yundersection7520oftheIn- ternal Rev enue Code of 1986 (Code) to reflect th e most recent mortality experi- ence avail able. In Genera l Section 7 520, effective for transfers for which the valuation date is after April 30, 1989, pro vides generally that the value of an annui ty, an interest for life or a term of years, a nd a remainder or reversionary in- terest i s to be determined under tables pub- lished b y the Secretary by using an inter- est rate (rounded to the nearest two-tenths of one p ercent) equal to 120 percent of the Federa l midterm rate in effect under sec- tion 12 74(d)(1) for the month in which the valuat ion date falls. Section 7520(c)(3) di- rected the Secretary to issue tables not later than D ecember 31, 1989, utilizing the then most r ecent mortality experience. There- after , the Secretary is directed to revise these tables not less frequently than once each 1 0 years to take into account the most rece nt mortality experience available as of the t ime of the revision. Thes etemporaryregulations, REG– 107845–08, incorporate revised Ta- bleS(SingleL ife Remainder Factors) and Table U(1) (Unitrust Single Life Re- mainder Facto rs), effective for transfers for which the valuation date is on or after May 1, 2009, b ased on data compiled from the 2000 cens us as set forth in Life Table 2000CM, and m ake conforming amend- ments to var ious sections to reflect the revised tab les. At the same time, in the portions of these regulations that are final regulation s, REG–105643–09, the current tables, eff ective for transfers for which the valuation date is after April 30, 1999, and before May 1, 2009, are moved to sections containin g 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 experi- ence, are not changed. Internal Revenue Service P ublications 1457“Actuarial Val- uations V ersion 3A”(forthcoming 2009), 1458“Ac tuarial Valuations Version 3B” (forthc oming 2009), and 1459“Actuar- ial Valu ations Version 3C”(forthcoming 2009) wi ll contain a complete set of actuar- ial tab les that include factors not contained in the t emporary regulations (for example, annuit y and life interest factors). These public ations will be available beginning May 1, 2 009, at no charge, electronically via the IRS Internet site atwww.irs.gov. The fol lowing chart summarizes the ap- plica ble interest rates and the citations to textu al materials and tables for the various perio ds covered under the current regula- tions : 2009–20 I.R.B.942May 18, 2009 Cross Reference to Regulation Sections Valuation P eriod Interest R ate Regulation S ectionTable Section 642: Valuation, in general-1.642(c)–6 before 01/01/52 4%1.642(c)–6A(a) 01/01/52 - 12/31/703.5% 1.642(c)–6A(b) 01/01/71 - 11/30/836%1.642(c)–6A(c) 12/01/83 - 04/30/8910%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 - 12/31/703.5% 1.664–4A(b) 01/01/71 - 11/30/836%1.664–4A(c) 12/01/83 - 04/30/8910%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 - 12/31/703.5% 20.2031–7A(b) 01/01/71 - 11/30/836%20.2031–7A(c) 12/01/83 - 04/30/8910%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 C M 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 2 512: Valuatio n, 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 - 04/30/8910% 25.2512–5A(d) 05/01/8 9 - 04/30/99 §752025.2512 –5A(e) 05/01/99 - 04/30/09§752025.2512–5A(f) on or after 05/01/09§752025.2512–5T(d) Effective Dates These regulations are applicable in the case of annuities, interests for life or terms of years, and remainder or reversionary in- terests valued as of a date on or after May 1, 2009. Transitional Rules The regulations provide certain transi- tional rules intended to alleviate any ad- verse consequences resulting from the pro- posed regulatory change. For gift tax pur- poses, if the date of a transfer is on or after May 1, 2009, but before July 1, 2009, the donor may choose to determine the value of the gift (and/or any applicable charita- ble deduction) under tables based on either Life Table 90CM or Table 2000CM. Sim- ilarly, for estate tax purposes, if the dece- dent dies on or after May 1, 2009, but be- fore July 1, 2009, the value of any inter- est (and/or any applicable charitable de- May 18, 20099432009–20 I.R.B. duction) may be determined in the discre- tion of the decedent’s executor under ta- bles based on either Life Table 90CM or Table 2000CM. However, the section 7520 interest rate to be utilized is the appropri- aterateforthemonthinwhichtheval- uation date occurs, subject to the follow- ing special rule for certain charitable trans- fers. 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 char- itable deduction, if the valuation date oc- curs on or after May 1, 2009, and before July 1, 2009, and the executor or donor elects under section 7520(a) to use the sec- tion 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 in- terest rate for May 2009 or for June 2009, then the tables based on either Table 90CM or Table 2000CM may be used. How- ever, 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 sec- tion 7520(a). In addition, for estate tax purposes, the estate of a mentally incompetent decedent may elect to value the property interest in- cluded in the gross estate either under the mortality table and interest rate in effect at the time the decedent became mentally in- competent or under themortality table and interest rate in effect on the decedent’s date of death if the decedent was under a men- tal incapacity that existed on May 1, 2009, and continued uninterrupted until the dece- dent’s death, or the decedent died within 90 days after regaining competency on or af- ter May 1, 2009. Special Analyses It has been determined that this Trea- sury decision is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. For applicability of the Regulatory Flexi- bility Act, please refer to the cross-refer- enced notice of proposed rulemaking pub- lished elsewhere in this Bulletin. Pursuant to section 7805(f) of the Internal Revenue Code, these regulations have been submit- ted 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 regula- tions 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 develop- ment. ***** 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 part1isamendedbyaddingentriesinnu- merical 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 fol- lows: §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 fur- ther 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: §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 fur- ther guidance, see §1.170A–12(a) through (b)(1). (b)(2)Computation of depreciation fac- tor. If the valuation of the remainder in- terest in depreciable property is dependent upon the continuation of one life, a spe- cial factor must be used. The factor deter- mined under this paragraph (b)(2) is car- ried to the fifth decimal place. The spe- cial factor is to be computed on the ba- sis of the interest rate and life contingen- cies prescribed in §20.2031–7T (or for pe- riods 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 deter- mining the present value of a remainder interest following one life and an exam- ple describing the computation are con- tained in Internal Revenue Service Pub- lication 1459,“Actuarial Valuations Ver- sion 3C”(2009). This publication will be available beginning May 1, 2009, at no charge, electronically via the IRS In- ternet site atwww.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 computa- tion are contained in Internal Revenue Ser- vice 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 computa- tion are contained in Internal Revenue Ser- vice Publication 1459,“Actuarial Values, Gamma Volume,”(8–89). These publi- cations are no longer available for pur- chase from the Superintendent of Docu- ments, United States Government Printing Office. However, they may be obtained by requesting a copy from: CC:PA:LPD:PR (IRS Publication 1459), Room 5205, Inter- nal 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 2009–20 I.R.B.944May 18, 2009 under certain circumstances). Otherwise, in the case of the valuation of a remainder interest following one life, the special fac- tor may be obtained through use of the fol- lowing formula: Where: 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). (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 resi- dence, 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 prop- erty 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). There- fore, the value of the remainder interest is $28,320.60. (c) through (e) [Reserved]. For further guidance, see §1.170A–12(c) through (e). (f)Effective/applicability date. Para- graphs (b)(2) and (b)(3) apply to all con- tributions 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: 1. Paragraph (d) is removed. 2. Paragraph (e) is redesignated as para- graph (f) of §1.642(c)–6A. 3. New paragraphs (d) and (e) are added. 4. Paragraph (f) is revised. The revisions and addition read as fol- lows: §1.642(c)–6 Valuation of a remainder interest in property transferred to a pooled income fund. ***** (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 re- mainder interest in property transferred to a pooled income fund for which the valu- ation date is before May 1, 2009, is deter- mined under the following sections: Valuation Dates AfterBefore Applicable Regulations - 01–01–52 1.642(c)–6A(a) 12–31–51 01–01–711.642(c)–6A(b) 12–31–7012–01–831.642(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, 20099452009–20 I.R.B. after May 1, 2009, the present value of a remainder interest is determined under this section. See, however, §1.7520–3(b) (re- lating 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 sec- tion. For purposes of the computations un- der 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 men- tally 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 compe- tency 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 trans- fers 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 val- uation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actu- arial 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 ex- ecutor, 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 ac- tuarial 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 includi- ble 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 inter- est in property transferred to a pooled in- come fund is computed on the basis of— (i) Life contingencies determined from the values oflxthat are set forth in Ta- ble 2000CM in §20.2031–7T(d)(7) (see §20.2031–7A for certain prior periods); and (ii) Discount at a rate of interest, com- pounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immedi- ately 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 in- come 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 considereda 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 antic- ipated with the purpose of obtaining an excessive charitablededuction, 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 in- come 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- tion 7520 rates for the 3 calendar years im- mediately 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 de- termining the present value of a remainder interest that is dependent on the termi- nation 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 remain- der 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 atwww.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 pro- vided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair mar- ket value of the property on the valuation date by the appropriate remainder factor. (ii) This paragraph (e)(5) may be illus- trated by the following example: Example. A, who is 54 years and 8 months, trans- fers $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 pre- ceding 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, com- puted as follows: 2009–20 I.R.B.946May 18, 2009 Factorat9.4percentforage55...................... .16192 Factorat9.6percentforage55.......................15755 Difference .......................................00437 Interpolation adjustment: 9 .47%-9.4% =x 0.2%.00437 x = .00153 Factorat9.4percentforage55...................... .16192 Less:Interpolationadjustment ...................... . 00153 Interpolatedfactor .................................16039 Present value of remainder interest: ($100,000X.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 termi- nation of one life in the case of a transfer to a pooled income fund is determined by use of the following Table S: 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% 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, 20099472009–20 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.948May 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, 20099492009–20 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.950May 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, 20099512009–20 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.952May 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, 20099532009–20 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.954May 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, 20099552009–20 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.956May 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 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 May 18, 20099572009–20 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.958May 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, 20099592009–20 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.960May 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, 20099612009–20 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.962May 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 (f)Effective/applicability date.This section applies on or after May 1, 2009. (g)Expiration date. This section ex- pires on or before May 1, 2012. Par. 6. The undesignated center head- ing 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: 1. Revising the section heading. 2. Amending newly-designated para- graph (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 fol- lows: §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 trans- fers 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) (re- lating 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 sec- tion. For purposes of the computations un- der 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, 1999, the decedent was men- tally 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 re- mainder interest is determined as if the val- uation 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 trans- fers 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 in- terest rate for the month in which the val- uation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actu- arial tables under either paragraph (e)(5) or (f)(6) of this section, at the option of May 18, 20099632009–20 I.R.B. 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- bles under either paragraph (e)(5) or (f)(6) of this section, the donor or decedent’s ex- ecutor 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 re- spect to the same transfer must be deter- mined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be val- ued based on the same tables). (3)Present value of a remainder inter- est. The present value of a remainder in- terest in property transferred to a pooled income fund is computed on the basis of — (i) Life contingencies determined from the values oflxthat are set forth in Table 90CM in §20.2031–7A(f)(4); and (ii) Discount at a rate of interest, com- pounded 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 re- turn. However, where the taxable year is less than 12 months, the provisions of §1.642(c)–6T(e)(3)(ii) apply for the deter- mining 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 determin- ing the highest yearly rate of return when the pooled income fund has been in exis- tence less than three taxable years. (5)Computation of value of remainder interest. The factor that is used in de- termining the present value of a remain- der interest that is dependent on the termi- nation 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 remain- der interest is based. Table S in paragraph (f)(6) of this section includes factors for yearly rates of return from 4.2 to 14 per- cent. Many actuarial factors not contained in Table S in paragraph (f)(6) of this sec- tion are contained in Table S in Internal Revenue Service Publication 1457,“Actu- arial Values, Book Aleph,”(7–99). Publi- cation 1457 is no longer available for pur- chase from the Superintendent of Docu- ments, United States Government Printing Office. However, pertinent factors in this publication may be obtained by a written request to: CC:PA:LPD:PR (IRS Publica- tion 1457), Room 5205, Internal Revenue Service, P.O.Box 7604, Ben Franklin Sta- tion, Washington, DC 20044. For other sit- uations, see §1.642(c)–6(b). If the yearly rate of return is a percentage that is be- tween 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 multi- plying the fair market value of the property on the valuation date by the appropriate re- mainder factor. For an example of a com- putation of the present value of a remain- der 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 in- terest dependent on the termination of one life in the case of a transfer to a pooled in- come fund is determined by use of the fol- lowing tables: TABLES.—BASEDONLIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS [Applicable After April 30, 1999, and Before May 1, 2009] ***** (7)Effective/applicability dates. Para- graphs (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 para- graph (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 (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 char- itable 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 mor- tality 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 regula- tions 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 inter- est 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) (relat- ing to exceptions to the use of prescribed tables under certain circumstances). ***** (e)Effective/applicability date. Para- graph (c)(1) applies after April 30, 1989. Par. 9. Section 1.664–4 is amended as follows: 1. Paragraph (a)(1) is revised. 2. Paragraph (d) is removed. 3. The heading for paragraph (e) is redesignated as the heading for §1.664–4A(f). 4.Paragraphs (e)(1), (e)(2), (e)(5), and (e)(7) are redesignated as 2009–20 I.R.B.964May 18, 2009 §1.664–4A(f)(1), (f)(2), (f)(5) and (f)(6), respectively. 5. New paragraphs (d), (e)(1), (e)(2), and (e)(5) are added. 6. The heading and introductory text of paragraph (e)(6), preceding Table D, is revised. 7. New paragraph (e)(7) is added. 8. Paragraph (f) is revised. The additions and revision read as fol- lows: §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 fur- ther 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 ta- bles under certain circumstances). Many actuarial factors notcontained in the fol- lowing 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 atwww.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 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 oflx 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 con- tained 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 fur- ther guidance, see §1.664–4(a)(2) through (c). (d)Valuation. The fair market value of a remainder interest in a charitable remain- der 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 sec- tion. 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: Valuation Dates AfterBefore Applicable Regulations - 01–01–52 1.664–4A(a) 12–31–51 01–01–711.664–4A(b) 12–31–7012–01–831.664–4A(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) (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 trans- fers for which the valuation date is on or after May 1, 2009, the present value of a re- mainder interest is determined under para- graphs (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 excep- tions to the use of the prescribed tables un- der 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 men- tally 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 compe- tencyonorafterMay1,2009,thepresent 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 trans- fers 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 May 18, 20099652009–20 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 un- der 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 ac- tuarial 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 individ- ual, 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 indi- vidual 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 appro- priate table, 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 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 Decem- ber 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 pay- out 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: Factorat7.6percentatage45....................... .11141 Factorat7.8percentatage45........................10653 Difference .......................................00488 Interpolation adjustment: 7 .627%-7.6% =x 0.2%.00488 x = .00066 Factorat7.6percentatage45....................... .11141 Less:Interpolationadjustment ....................... 00066 InterpolatedFactor ............................... .11075 Present value of remainder interest: ($100,000X.11075) .............................. $11,075.00 (6) [Reserved]. For further guidance, see §1.664–4(e)(6). (7)Actuarial Table U(1) for transfers for which the valuation date ison 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 remain- der unitrust interest that is dependent on the termination of a life interest is deter- mined by using the section 7520 rate, Ta- ble 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 actu- arial factors not contained in the follow- ing tables are contained in Internal Rev- enue Service Publication 1458,“Actuarial Valuations Version 3B”(2009). This pub- lication will be available beginning May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov. 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.966May 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, 20099672009–20 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.968May 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, 20099692009–20 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.970May 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, 20099712009–20 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.972May 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, 20099732009–20 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.974May 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, 20099752009–20 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.976May 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, 20099772009–20 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 (f)Effective/applicability date.This section applies on or after May 1, 2009. (g)Expiration date. This section ex- pires on or before May 1, 2012. Par. 11. The undesignated center head- ing immediately preceding §1.664–4A is revised to read as follows: Unitrust ActuarialTables Applicable Before May 1, 2009 Par. 12. Section 1.664–4A is amended as follows: 1. The section heading is revised. 2. The heading of newly-designated paragraph (f) is revised. 3. Newly-designated paragraphs (f)(1) and (f)(2) are revised. 4. New paragraphs (f)(3) and (f)(4) are added. 5. Newly-designated paragraph (f)(5) is revised. 6. In newly-designated paragraph (f)(6), the heading and the first paragraph are revised. 7. The heading of Table U(1) is revised. 8. Paragraph (f)(7) is added. The additions and revisions read as fol- lows: §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 valu- ation date is after April 30, 1999, and be- fore May 1, 2009, the present value of a re- mainder interest is determined under para- graphs (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 excep- tions to the use of the prescribed tables un- der 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 men- tally 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 re- mainder interest under this section is deter- mined as if the valuation date with respect to the decedent’s gross estate is either be- fore 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 trans- fers 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 un- der this section by use of the section 7520 interest rate for the month in which the val- uation date occurs (see §§1.7520–1(b) and 1.7520–2(a)(2)) and the appropriate actu- arial 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- bles under either paragraph (e)(6) or (f)(6) of this section, the donor or decedent’s ex- ecutor 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 re- spect to the same transfer must be deter- mined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be val- ued 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 us- ing the appropriate Table F, contained in §1.664–4(e)(6), for the section 7520 inter- est rate applicable to the transfer. If the in- terest 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 per- cent, see §1.664–4(b). See §1.664–4(e) for rules applicable in determining the ad- justed payout rate. (4)Period is a term of years.Ifthepe- riod described in §1.664–3(a)(5) is a term of years, the factor that is used in deter- mining the present value of the remainder interest for transfers for which the valua- tion date is after April 30, 1999, and be- fore 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 ad- justed payout rate is an amount that is be- tween adjusted payout rates for which fac- tors are provided in Table D, a linear inter- polation 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 deter- mined under this paragraph. Generally, for purposes of this section, the valuation date 2009–20 I.R.B.978May 18, 2009 is, in the case of aninter vivostransfer, 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 ad- ditional rules regarding the valuation date. See §1.664–4(e)(4) for an example that il- lustrates 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 fac- tor in Table U(1) in paragraph (f)(6) of this section under the appropriate adjusted pay- out. For purposes of the computations de- scribed 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 ta- ble, a linear interpolation must be made. The rules provided in §1.664–4T(e)(5) ap- ply 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 ac- tuarial 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 re- mainder unitrust interest that is dependent on the termination of a life interest is deter- mined 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 actu- arial factors not contained in the follow- ing tables are contained in Internal Rev- enue Service Publication 1458,“Actuar- ial Values, Book Beth,”(7–1999). Publi- cation 1458 is no longer available for pur- chase from the Superintendent of Docu- ments, United States Government Printing Office. However, pertinent factors in this publication may be obtained by a written request to: CC:PA:LPD:PR (IRS Publica- tion 1458), Room 5205, Internal Revenue Service, P.O. Box 7604, Ben Franklin Sta- tion, 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. Para- graphs (f)(1) through (f)(6) apply after April 30, 1999, and before May 1, 2009. Par. 13. Section 1.7520–1 is amended by: 1. Revising the section heading. 2. Revising paragraphs (a)(1) and (a)(2). 3. Removing the last two sentences of paragraph (b)(2) and adding a new sen- tence at the end of the paragraph. 4. Revising paragraph (c)(1). 5. Revising the heading and introduc- tory text of paragraph (c)(2). 6. Revising paragraph (d). The revisions and additions read as fol- lows: §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 sec- tion and in §1.7520–3 (relating to excep- tions to the use of prescribed tables under certain circumstances), in the case of cer- tain 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 inter- ests), remainders, and reversions is their present value determined under this sec- tion. 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 sec- tion. (2) For a transfer to a pooled in- come fund prior to May 1, 2009, see §1.642(c)–6A 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. (c) * * * (1) [Reserved]. For further guidance, see §1.7520–1T(c)(1). (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 publica- tions are no longer available for purchase from the Superintendent of Documents, United States Government Printing Of- fice; 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 sec- tion and in §1.7520–3 (relating to excep- tions to the use of prescribed tables under certain circumstances), in the case of cer- tain transactions after April 30, 1989, sub- ject to income tax, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), re- mainders, and reversions is their present value determined under this section. See §20.2031–7T(d) (and, for certain prior pe- riods, §20.2031–7A) for the computation of the value of annuities, unitrust inter- ests, life estates, terms for years, remain- ders, and reversions, other than interests described in paragraphs (a)(2) and (a)(3) of this section. (2) For a transfer to a pooled in- come fund on or after May 1, 2009, see §1.642(c)–6T(e) (or, for certain prior pe- riods, §1.642(c)–6A) with respect to the valuation of the remainder interest. (3) [Reserved]. For further guidance, see §1.7520–1(a)(3). May 18, 20099792009–20 I.R.B. (b)(1) [Reserved]. For further guid- ance, see §1.7520–1(b)(1). (2)Mortality component.Themortality 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 sec- tion will be revised periodically and the re- vised 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 compo- nent 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. (c) [Reserved]. For further guidance, see §1.7520–1(c). (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 in- terest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for ac- tuarial factors for one life applicable to val- uation dates before May 1, 2009. Sec- tion 1.664–4(e)(6) contains Table F (pay- out 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 deter- mining 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) con- tains Table B (actuarial factors used in de- termining the present value of an inter- est for a term of years), Table K (annu- ity end-of-interval adjustment factors), and Table J (term certain annuity beginning- of-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 re- versions. 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 datesonorafterMay1,2009.Thefol- lowing documents are available beginning May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov: (i) Internal Revenue Service Publica- tion 1457,“Actuarial Valuations Version 3A”(2009). This publication includes ta- bles of valuation factors, as well as exam- ples that show how to compute other valu- ation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, mea- suredbyoneortwolives. Thesefactors mayalsobeusedinthevaluationofinter- ests in a charitable remainder annuity trust as defined in §1.664–2 and a pooled in- come fund as defined in §1.642(c)–5. (ii) Internal Revenue Service Publica- tion 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 Publica- tion 1459,“Actuarial Valuations Version 3C”(2009). This publication includes tables for computing depreciation adjust- ment factors. See §1.170A–12T. (d)Effective/applicability date.This section applies on or after May 1, 2009. (e)Expiration date. This section ex- pires 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 numer- ical 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 ap- pear in the regulations under section 2031. §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, in- terests for life or term of years, and remain- der or reversionary interests. §20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (tem- porary). §20.2031–8 Valuation of certain life in- surance and annuity contracts; valuation of shares in an open-end investment com- pany. §20.2031–9 Valuation of other prop- erty. 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 es- tates 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: 1. Revising paragraphs (c), (d)(1), (d)(2), (d)(3), (d)(4), (d)(5), and (e). 2. Redesignating paragraph (d)(7) as paragraph (f)(4) of §20.2031–7A. 3. Adding new paragraph (d)(7). The revisions and additions read as fol- lows: §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: 2009–20 I.R.B.980May 18, 2009 §20.2031–7T Valuation of annuities, interests for life or term of years, and remainder or reversionary interests (temporary). (a)through(b)[Reserved].Forfurther 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 es- tates 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 annu- ities, life estates, terms of years, remain- ders, and reversions for estates of dece- dents for which the valuation date of the gross estate is before May 1, 2009, is de- termined under the following sections: Valuation Dates AfterBeforeApplicable Regulations - 01–01–52 20.2031–7A(a) 12–31–51 01–01–7120.2031–7A(b) 12–31–7012–01–8320.2031–7A(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) (d)Actuarial valuations on or after May 1, 2009—(1)In general. Except as other- wise provided in paragraph (b) of this sec- tion and §20.7520–3(b) (pertaining to cer- tain limitations on the use of prescribed ta- bles), if the valuation date for the gross es- tate 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 fac- tors are derived by using the appropri- ate section 7520 interest rate and, if ap- plicable, the mortality component for the valuation date of the interest that is be- ing valued. For purposes of the computa- tions 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 inter- est 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 inter- est 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 indi- vidual, 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 In- ternal 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 inter- ests, 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 in- come of certain property, or to use cer- tain nonincome-producing property, for a term of years or for the life of one indi- vidual, 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 corre- sponds to the applicable section 7520 in- terest rate and term-of-years or life interest period). Internal Revenue Service Publi- cation 1457 includes actuarial factors for a remainder interest after a term of years in Table B and after the life of one indi- vidual 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 Ser- vice Publication 1457 (or any other reli- able source of term-of-years and life in- terest actuarial factors) is not conveniently available, an actuarial factor for the inter- est may be derived mathematically. This actuarial factor may be derived by sub- tracting the correlative remainder factor (that corresponds to the applicable sec- tion 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 ob- taining actuarial factors for other types of term-of-years and life interests, see para- graph (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 fac- tor (that corresponds to the applicable section 7520 interest rate and annuity pe- May 18, 20099812009–20 I.R.B. riod). Internal Revenue Publication 1457 includes actuarial factors for a remain- der 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 Ta- ble S in paragraph (d)(7) of this section (or in §20.2031–7A). If Internal Revenue Service Publication 1457 (or any other re- liable 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 sub- tracting 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 theapplicable adjust- ment factor as contained in Table K in §20.2031–7(d)(6) for payments made at the end of the specified periods. The pro- visions 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 indi- vidual aged 72 is 8.3495 (1.00000 minus .53243, di- vided 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). (C) If an annuity is payable at the be- ginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is com- puted by multiplying the aggregate amount payable annually by the annuity factor de- scribed in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Ta- ble J in §20.2031–7(d)(6) at the appropri- ate 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 pe- riod, determined as provided in this para- graph (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 dece- dent dies on or after May 1, 2009, and if on May 1, 2009, the decedent was men- tally 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, re- mainders, 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 ei- ther paragraph (d)(7) of this section or §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 actuar- ial 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 indi- vidual transaction and with respect to all transfers occurring on the valuation date (for example, gift and income tax chari- table 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 in- cluded in §20.2031–7(d)(6) or in para- graph (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 sit- uations. This publication will be available beginning May 1, 2009, at no charge, elec- tronically via the Internal Revenue Service Internet site atwww.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 ap- plicable 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. (5)Examples. The provisions of this section are illustrated by the following ex- amples: Example 1.Remainder payable at an individual’s death. The decedent, or the decedent’s estate, was en- titled 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 47yearsand5monthsold.Inthemonthinwhichthe decedent died, the section7520 rate was 6.2 percent. Under Table S in paragraph (d)(7) of this section, 2009–20 I.R.B.982May 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 per- cent for determining the present value of the remain- der interest at the death of a person age 46 (the num- ber of years nearest B’s actual age) is .24774. By con- verting 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 annu- ity 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 dece- dent’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 an- nuity factor, as described in paragraph (d)(2)(iv)(A) of this section, the factor for the present value of an annuity for a term of 5 years is 3.8102 (1.00000 mi- nus .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 lim- itations on the use of prescribed tables), for determination of the present value of an interest that is dependent on the ter- mination of a life interest, Table 2000CM and Table S (single life remainder factors applicable where thevaluation 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 in- terest rate component is between 0.2 and 14 percent. 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% 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 May 18, 20099832009–20 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 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 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 2009–20 I.R.B.984May 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 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 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 May 18, 20099852009–20 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 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 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 2009–20 I.R.B.986May 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 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 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 May 18, 20099872009–20 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% 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 2009–20 I.R.B.988May 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 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 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 May 18, 20099892009–20 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 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 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 2009–20 I.R.B.990May 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% 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 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 May 18, 20099912009–20 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 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 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 2009–20 I.R.B.992May 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 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 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 May 18, 20099932009–20 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 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 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 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 2009–20 I.R.B.994May 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 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 May 18, 20099952009–20 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 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 2009–20 I.R.B.996May 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 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 May 18, 20099972009–20 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 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 2009–20 I.R.B.998May 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 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 Table 2000CM AgeAgeAge xl x xl x xl x 010000037969217466882 1 99305 3896767 7564561 2 99255 39966007662091 399222409641977 59476 499197419622378 56721 5 99176429601079 53833 6 99158 43 95782 80 50819 79914044 95535 8147694 899124 4595268 82 44475 99911046949818341181 109909747946708437837 11 99085 48 9433585 34471 129907349 93975 8631114 13 990575093591 8727799 1499033 51 9318088 24564 15 98998 52 927418921443 16 9895053 922709018472 1798891 54 9176291 15685 1898822 55 912119213111 19 9874556 906079310773 2098664 57 89947948690 21 98577588922595 6871 May 18, 20099992009–20 I.R.B. Table 2000CM AgeAgeAge 22 9848559 8844196 5315 239839060 87595 974016 24 98295 618668198 2959 25 9820262 85691 992122 269811163846201001477 279802264 83465 101997 2897934 65 82224102 650 29978446680916103410 30 97750 67 79530 104248 31 97652 68 78054105 144 32 97549 697647810681 3397441707479410743 3497324717300110822 35 97199727109210911 36 97065 73 69056 1100 (e)Effective/applicability date.This section applies on or after May 1, 2009. (f)Expiration date. This section ex- pires on or before May 1, 2012. Par. 19. The undesignated center head- ing 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: 1. Revising the section heading. 2. Adding paragraphs (f)(1), (f)(2), and (f)(3). 3. In newly-designated paragraph (f)(4), the heading and introductory text paragraph is revised. 4. The heading of Table S in newly- designated paragraph (f)(4) is revised. 5. The heading of Table 90CM in newly-designated paragraph (f)(4) is re- vised. 6. Paragraph (f)(5) is added. The revisions and additions read as fol- lows: §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, re- mainders, and reversionary interests is the present value of the interests determined by use of standard or special section 7520 actuarial factors and the valuation method- ology described in §20.2031–7T(d). These factors are derived by using the appropri- ate section 7520 interest rate and, if appli- cable, the mortality component for the val- uation date of the interest that is being val- ued. See §§20.7520–1 through 20.7520–4. See paragraph (f)(4) of this section for de- termination 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 incom- petent so that the disposition of the dece- dent’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 com- petency, 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 de- termined either under this section or under the corresponding section applicable at the time the decedent became mentally incom- petent, at the option of the decedent’s ex- ecutor. 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- ket value of annuities, life estates, remain- ders, and reversions based on one or more measuring lives included in the gross es- tate 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 ei- ther 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 un- der either paragraph (e)(4) or paragraph (f)(4) of this section, the decedent’s execu- tor 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 re- spect to the same transfer must be deter- mined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be val- ued based on the same tables). (3)Publications and actuarial compu- tations by the Internal Revenue Service. Many standard actuarial factors not in- cluded in paragraph (f)(4) of this section or in §20.2031–7(d)(6) are included in In- ternal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,”(7–99). Publication 1457 also includes examples that illustrate how to compute many spe- cial factors for more unusual situations. Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government 2009–20 I.R.B.1000May 18, 2009 Printing Office. However, pertinent fac- tors in this publication may be obtained from: CC:PA:LPD:PR (IRS Publication 1457), Room 5205, Internal Revenue Ser- vice, P.O.Box 7604, Ben Franklin Station, Washington, DC 20044. If a special factor is required in the case of an actual dece- dent, the Internal Revenue Service may furnish the factor to the executor upon a request for a ruling. The request for a rul- ing 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 ap- plicable 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. (4)Actuarial tables. Except as pro- vided in §20.7520–3(b) (pertaining to cer- tain limitations on the use of prescribed ta- bles), Life Table 90CM and Table S (Sin- gle 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 inter- est rate component is between 4.2 and 14 percent. Table S and Table 90CM are as follows: TableS.—BasedonLifeonLifeTable 90CM Single Life Remainder Factors [Applicable After April 30, 1999, and Before May 1, 2009] ***** Table 90 CM.—Applicable After April 30,1999,andBeforeMay1,2009 ***** (5)Effective/applicability dates. Para- graphs (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 pre- scribed 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 alter- nate 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 dece- dent’s death would, as illustrated inExam- ple 1of §20.2031–7T(d)(5), be $9,336.00 ($50,000 x .18672).If, because of eco- nomic 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 remain- der 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. Para- graph (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) * * * (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 sec- tion 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 indi- viduals is generally effective in the case of transfers pursuant to wills and revo- cable trusts when the decedent dies on or after April 4, 2000. Two exceptions from the application of this rule in para- graphs (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 excep- tion is for a decedent who was on April 4, 2000, under a mental disability that pre- vented 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 com- petence, 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 cre- ated 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 May 18, 200910012009–20 I.R.B. 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 trans- fer 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 Publi- cation 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 para- graph (f)(2) of this section is to be deter- mined 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 dece- dents 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) andExample 4of 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 to- tal present value of the payments by the an- nual payment. From the quotient so ob- tained, the expected annuity term is de- rived 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 in- terest rate, contained in Publication 1457, Actuarial Valuations Version 3A.Acopy of this publication is available beginning May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov. 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 1through3. [Reserved]. For further guidance, see §20.2056A–4(d) Examples 1through3. 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 employ- ees’ 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 per- son 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 hypothet- ical fund that has a present value and a payout cor- responding 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 ex- haust a hypothetical fund of $818,164.80. The term certain annuity factor of 11.0625 falls between the an- nuity factors for 18 and 19 years in a 6.0 percent term certain annuity table (Column 1 of Table B, Publi- cation 1457,Actuarial Valuations Version 3A,which may be obtained on the IRS Internet site). Accord- ingly, 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 thisExample 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 mari- tal 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 pay- ment to a QDOT and the executor files the Informa- tion Statement described in paragraph (c)(5) of this 2009–20 I.R.B.1002May 18, 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 de- scribed in paragraph (c)(5) of this section and the Pay- ment 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. Para- graph (c)(4)(ii)(B) andExample 4in para- graph (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) andExample 4in paragraph (d) of this section expire on or before May 1, 2012. Par. 27. Section 20.7520–1 is amended by: 1. Revising the section heading. 2. Revising the second sentence of paragraph (a)(1) and revising paragraph (a)(2). 3. Removing the last two sentences of paragraph (b)(2) and adding a new sen- tence at the end of the paragraph. 4. Revising paragraphs (c)(1), (c)(2), and (d). The revisions and additions read as fol- lows: §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)***Forperiodsprior to May 1, 2009, see §20.2031–7A for the computation of the value of annuities, uni- trust interests, life estates, terms for years, remainders, and reversions, other than in- terests described in paragraphs (a)(2) and (a)(3) of this section. (2) For a transfer to a pooled in- come fund prior to May 1, 2009, see §1.642(c)–6A (Income Tax Regulations) with respect to the valuation of the re- mainder interest. ***** (b) * * * (2) * * * For decedents’ estates with val- uation dates after April 30, 1989, and be- fore May 1, 2009, the mortality component tables are contained in §20.2031–7A. (c) * * * (1) [Reserved]. For further guidance, see §20.7520–1T(c)(1). (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 publica- tions are no longer available for purchase from the Superintendent of Documents, United States Government Printing Of- fice; 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. 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 sec- tion and in §20.7520–3 (relating to excep- tions to the use of prescribed tables under certain circumstances), in the case of es- tates of decedents with valuation dates af- ter April 30, 1989, the fair market value of annuities, interests for life or for a term of years (including unitrust interests), re- mainders, and reversions is their present value determined under this section. See §20.2031–7T(d) (and, for certain prior pe- riods, §20.2031–7A) for the computation of the value of annuities, unitrust inter- ests, life estates, terms for years, remain- ders, 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 guid- ance, see §20.7520–1(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 sec- tion will be revised periodically and the re- vised 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 com- ponent 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. (c) [Reserved]. For further guidance, see §20.7520–1(c). (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 in- terest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for sin- gle life remainder factors applicable to val- uation dates before May 1, 2009. Sec- tion 1.664–4(e)(6) contains Table F (pay- out 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 deter- mining 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) con- tains Table B (actuarial factors used in de- termining the present value of an inter- est for a term of years), Table K (annu- ity end-of-interval adjustment factors), and Table J (term certain annuity beginning- of-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 re- versions. See §20.2031–7A for single life remainder factors 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.Thefol- lowing documents areavailable beginning May 18, 200910032009–20 I.R.B. May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov: (i) Internal Revenue Service Publica- tion 1457,“Actuarial Valuations Version 3A”(2009). This publication includes ta- bles of valuation factors, as well as exam- ples that show how to compute other valu- ation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, mea- suredbyoneortwolives. Thesefactors may also be used in the valuation of inter- ests in a charitable remainder annuity trust as defined in §1.664–2 and a pooled in- come fund as defined in §1.642(c)–5. (ii) Internal Revenue Service Publica- tion 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 Publica- tion 1459,“Actuarial Valuations Version 3C”(2009). This publication includes tables for computing depreciation adjust- ment factors. See §1.170A–12T. (d)Effective/applicability date.This section applies on or after May 1, 2009. (e)Expiration date. This section ex- pires 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 numer- ical 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, uni- trust interests, interests for life or term of years, and remainder or reversionary inter- ests. §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 in- surance and annuity contracts; valuation of shares in an open-end investment com- pany. §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 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 re- versionstransferredbygiftonorafterMay 1, 2009, is determined under paragraph (d) of this section. The present value of annu- ities, unitrust interests, life estates, terms of years, remainders, and reversions trans- ferred by gift before May 1, 2009, is deter- mined under the following sections: Transfers AfterBefore Applicable Regulations - 01–01–5225.2512–5A(a) 12–31–51 01–01–71 25.2512–5A(b) 12–31–7012–01–83 25.2512–5A(c) 11–30–83 05–01–8925.2512–5A(d) 04–30–89 05–01–9925.2512–5A(e) 04–30–99 05–01–0925.2512–5A(f) (d)Actuarial valuations on or after May 1, 2009—(1)In general. Except as other- wise provided in paragraph (b) of this sec- tion and §25.7520–3(b) (relating to excep- tions to the use of prescribed tables un- der certain circumstances), if the valua- tion 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 fac- tors are derived by using the appropriate section 7520 interest rate and, if applica- ble, the mortality component for the valua- tion date of the interest that is being valued. See §§25.7520–1 through 25.7520–4. The fair market value of a qualified annuity in- terest described in section 2702(b)(1) and a qualified unitrust interest described in sec- tion 2702(b)(2) is the present value of such interests determined under §25.7520–1(c). 2009–20 I.R.B.1004May 18, 2009 (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 de- termined under section 2702. If the donor assigns or relinquishes an annuity, life es- tate, 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 trans- ferred. However, see section 2519 for a special rule in the case of the assignment of an income interest by a person who re- ceived 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 charita- ble remainder annuity trust, as described in §1.664–2(a), is its present value deter- mined under §1.664–2(c). The fair market value of a remainder interest in a char- itable 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). (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 indi- vidual, 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 appropri- ate 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 in- cluded in §20.2031–7T(d)(7) and Internal Revenue Service Publication 1457. See §20.2031–7A containing Table S for valu- ation of interests before May 1, 2009. For information about obtaining actuarial fac- tors 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 in- come of certain property, or to use cer- tain nonincome-producing property, for a term of years or for the life of one indi- vidual, 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 corre- sponds to the applicable section 7520 in- terest rate and term-of-years or life interest period). Internal Revenue Service Publi- cation 1457 includes actuarial factors for a remainder interest after a term of years in Table B and after the life of one in- dividual in Table S (for one measuring life when the valuation date is on or af- ter 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 Ser- vice Publication 1457 (or any other reli- able source of term-of-years and life in- terest actuarial factors) is not conveniently available, an actuarial factor for the inter- est may be derived mathematically. This actuarial factor may be derived by sub- tracting 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 Ta- ble S (for the life of one individual) in §20.2031–7T(d)(7), as the case may be, from 1.000000. For information about ob- taining actuarial factors for other types of term-of-years and life interests, see para- graph (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 period). In- ternal Revenue Service Publication 1457 includes actuarial factors in Table B (for a remainder interest after an annuity payable 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 Ser- vice Publication 1457 (or any other reli- able source of annuity actuarial factors) is not convenientlyavailable, an annu- ity factor for a term of years or for one life may be derived mathematically. This annuity factor may be derived by sub- tracting 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 ad- justment factor set forth in Table K in §20.2031–7(d)(6) at the appropriate in- terest 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 inter- est payable at the death of an individual aged 68 is .42001. Converting the remainder factor to an an- nuity factor, as described above, the annuity factor for determining the present value of an annuity trans- ferred to an individual age 68 is 8.7877 (1.00000 mi- nus .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 May 18, 200910052009–20 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 be- ginning of annual, semiannual, quarterly, monthly, or weekly periods for a term of years, the value of the annuity is com- puted by multiplying the aggregate amount payable annually by the annuity factor de- scribed in paragraph (d)(2)(iv)(A) of this section; and the product so obtained is then multiplied by the adjustment factor in Ta- ble J in §20.2031–7(d)(6) at the appropri- ate 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 pe- riod, 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 oc- cur of the lapse of a specific number of years or the death of an individual may be computed with values from the tables in §§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 in- stallments 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 com- puting the present value of the retained annuity. The section 7520 rate for the month in which the trans- fer occurred is 5.8 percent. The present value of the donor’s retained interest is $42,575.65, determined as follows: 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 TABLE2000CMvalueatage60 .......... 87595 TABLE B value at 5.8 percent, 10 years . . . . . .569041 TABLEKvalueat5.8percent ............ 1.0143 Factor for donor’s retained interest at 5.8 percent: ( 1.00000-.34656)-(.569041X(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 (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 birth- day, is 60 years old, transfers $100,000 to a unitrust on January 1 st of a year after 2009. The trust instru- ment 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, for 10 years or until the prior death of the donor. The section 7520 rate for the January in which the trans- fer 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 deter- mined as follows: TABLEU(1)valueat5.6percent,age60.............. .33970 TABLEU(1)valueat5.6percent,age70.............. .48352 TABLE2000CMvalueatage70 .................... 74794 TABLE2000CMvalueatage60 .................... 87595 TABLEDvalueat5.6percent,10years............... .561979 Factor for donor’s retained interest at 5.6 percent: (1.000000 - .33970) - (.561979 X (74794/87595) X (1.000000 - .48352)) = .41247 TABLEU(1)valueat5.8percent,age60.............. .32846 TABLEU(1)valueat5.8percent,age70.............. .47241 TABLE2000CMvalueatage70 .................... 74794 TABLE2000CMvalueatage60 .................... 87595 TABLEDvalueat5.8percent,10years............... .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.1006May 18, 2009 Interpolation adjustment: 5 .720%-5.6% =x 0.2%.01122 x = .00673 Factorat5.6percent,age60 ........................ .41247 Plus:Interpolationadjustment ...................... . 00673 InterpolatedFactor ............................... .41920 Present value of donor’s retained interest: ($100,000X.41920) .............................. $41,920.00 (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 in- dividual 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 Inter- nal 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 publica- tion is available beginning May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov. If a special factor is required in the case of a com- pleted gift, the Internal Revenue Service may furnish the factor to the donor upon arequestforaruling. Therequestfora ruling must be accompanied by a recita- tion 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 ex- pires on or before May 1, 2012. Par. 33. The undesignated center head- ing 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 fol- lows: §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 in- terest 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 rever- sions 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 com- pute the present value of ordinary annuity, life, and remainder interests in property. These sections also refer to standard and special actuarial factors that may be nec- essary to compute the present value of similar interests in more unusual fact sit- uations. These factors and examples are also generally applicable for gift tax pur- poses 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 in- dividual 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 thesametables). (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 Inter- nal 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 Su- perintendent 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 May 18, 200910072009–20 I.R.B. 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 recita- tion 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. (4)Effective/applicability dates. Para- graphs (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].Forfurther 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 para- graphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this section that guaranteed annuity inter- ests or unitrust interests, respectively, may be payable for a specified term of years or for the life or lives of only certain individ- uals applies to transfers made on or after April 4, 2000. If a transfer is made on or after April 4, 2000, that uses an individ- ual other than one permitted in paragraphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this sec- tion, 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 inter- est. 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 annu- ity 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 trans- fer is made and must be completed within a reasonable time after it is commenced. A non-judicial reformation is permitted if ef- fective under state law, provided it is com- pleted by the date on which a judicial ref- ormation must be commenced. In the al- ternative, if a court, in a proceeding that is commenced on or before July 5, 2001, de- clares any transfer, made on or after April 4, 2000, and on or before March 6, 2001, null and void ab initio, the Internal Rev- enue 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: 1. Revising the section heading. 2. Revising the second sentence of paragraph (a)(1) and revising paragraph (a)(2). 3. Removing the last two sentences of paragraph (b)(2) and adding a new sen- tence at the end. 4. Revising paragraphs (c)(1), (c)(2), and (d). The revisions and additions read as fol- lows: §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. ***** (a)***(1)***Forperiodsprior to May 1, 2009, see §20.2031–7A for the computation of the value of annuities, uni- trust interests, life estates, terms for years, remainders, and reversions, other than in- terests 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. (c) * * * (1) [Reserved]. For further guidance, see §25.7520–1T(c)(1). (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 publica- tions are no longer available for purchase from the Superintendent of Documents, United States Government Printing Of- fice; 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. 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 sec- tion and in §25.7520–3 (relating to excep- tions to the use of prescribed tables under certain circumstances), in the case of cer- tain gifts after April 30, 1989, the fair mar- ket value of annuities, interests for life or for a term of years (including unitrust in- terests), remainders,and reversions is their present value determined under this sec- tion. See §20.2031–7T(d) (and, for cer- tain prior periods, §20.2031–7A) for the 2009–20 I.R.B.1008May 18, 2009 computation of the value of annuities, uni- trust interests, life estates, terms for years, remainders, and reversions, other than in- terests 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 guid- ance, see §25.7520–1(b)(1). (2)Mortality component.Themortal- ity component reflects the mortality data most recently available from the United States census. As new mortality data be- comes available after each decennial cen- sus, 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 compo- nent 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 be- fore May 1, 2009. (c) [Reserved]. For further guidance, see §25.7520–1(c). (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 in- terest in a pooled income fund as defined in §1.642(c)–5. See §1.642(c)–6A for sin- gle life remainder factors applicable to val- uation dates before May 1, 2009. Sec- tion 1.664–4(e)(6) contains Table F (pay- out 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 deter- mining 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) con- tains Table B (actuarial factors used in de- termining the present value of an inter- est for a term of years), Table K (annu- ity end-of-interval adjustment factors), and Table J (term certain annuity beginning- of-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 re- versions. See §20.2031–7A for single life remainder factors and mortality compo- nents 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 fol- lowing documents are available beginning May 1, 2009, at no charge, electronically via the IRS Internet site atwww.irs.gov: (i) Internal Revenue Service Publica- tion 1457,“Actuarial Valuations Version 3A”(2009). This publication includes ta- bles of valuation factors, as well as exam- ples that show how to compute other valu- ation factors, for determining the present value of annuities, life estates, terms of years, remainders, and reversions, mea- suredbyoneortwolives. Thesefactors mayalsobeusedinthevaluationofinter- ests in a charitable remainder annuity trust as defined in §1.664–2 and a pooled in- come fund as defined in §1.642(c)–5. (ii) Internal Revenue Service Publica- tion 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 Publica- tion 1459,“Actuarial Valuations Version 3C”(2009). This publication includes tables for computing depreciation adjust- ment factors. See §1.170A–12T. (d)Effective/applicability date.This section applies on or after May 1, 2009. (e)Expiration date. This section ex- pires on or before May 1, 2012. Par. 39. Section 25.7520–3 is amended by revising paragraph (b)(2)(v),Example 5and 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 1through4. [Reserved]. For further guidance, see §25.7520–3(b)(2)(v)Examples 1through 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 organi- zation 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 re- quire payments until the measuring life reaches age 110.Basedonasection7520interestrateof6.8per- cent, the determination of whether the annuity may exhaust the corpus before the annuity payments are made is computed as follows: May 18, 200910092009–20 I.R.B. Agetowhichlifeannuitymaycontinue .................. 110 less:Ageofmeasuringlifeatdateoftransfer.............. 6 0 Numberofyearsannuitymaycontinue................ 50 Annualannuitypayment ........................... $100,000.00 times: Annuity factor for 50 years derived from Table B (1-.037277/.068)................................ 1 4.1577 Presentvalueoftermcertainannuity..................... $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. Con- sequently, 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 pay- ments. (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 prin- cipal 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 ob- tained 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 para- graph (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 ill- ness and has at least a 50 percent probability of dy- ing within 1 year. The section 7520 interest rate for the month of the transfer is 7.6 percent, and the stan- dard 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, be- cause there is at least a 50 percent probability that the donor will die within 1 year, the standard sec- tion 7520 annuity factor may not be used to determine the present value of the donor’s annuity interest. In- stead, 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. Sec- tion 25.7520–3(a) is effective as of May 1, 1989. The provisions of paragraph (b) of this section, exceptExample 5in para- graph (b)(2)(v) and paragraph (b)(4), are effective with respect to gifts made after December 13, 1995.Example 5in para- graph (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: SectionRemoveAdd §1.170A–12(e)(2) following the formula Table 90 CM in §20.2031–7Table 2000CM in §20.2031–7T §1.170A–14(h)(4),Example 2,fourth sentence May 1, 1999May 1, 2009 §1.664–1(a)(6) introductory text§§1.664–4(e) and 1.664–4A(d) and (e)§§1.664–4T(e) and 1.664–4A 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.1010May 18, 2009 Part III. Administrative, Procedural, and Miscellaneous Extension of Date for Multiemployer Plans to Elect Relief Under Sections 204 and 205 of WRERA Notice 2009–42 I. Background and extension of date for making election On March 27, 2009, the Service is- sued Notice 2009–31, 2009–16 I.R.B. 856, providing guidance to multiem- ployer plans making elections described in sections 204 and 205 of the Worker, Retiree, and Employer Recovery Act of 2008, P.L. 110–458 (WRERA). Section IV.1 of the notice provided the following deadlines for making these elections: Pursuant to the authority granted to the Secretary and his delegate under section 204(c)(1)(A) of WRERA to pre- scribe the time and manner for making an election, an election under section 204 must be made by the later of April 30, 2009 and the date that is 30 days af- ter the due date of the annual certifica- tion of section 432 status for the elec- tion year. * * * Pursuant to the authority granted to the Secretary and his delegate under section 205(b)(1) to prescribe the time and manner for making an election un- dersection205,suchanelectionmust be made by the last day of the plan year as of which the election is be- ing made, or, if earlier, by the date a funding improvement plan, rehabilita- tion plan, or update is adopted that takes into account the election. However, in no event is the electionrequiredtobe made earlier than April 30, 2009. Some sponsors of multiemployer plans have identified a legitimate need for addi- tional time to make these elections in par- ticular situations. Accordingly, this no- tice hereby substitutes “June 30, 2009” for each reference to “April 30, 2009” in Sec- tion IV.1 of Notice 2009–31. In addition, if (1) as of the otherwise ap- plicable deadline (i.e., the deadline for a plan as modified by this notice) for making an election under section 204 or 205, a plan sponsor has been unable to reach agree- ment as to whether to make the election, so that the decision must be resolved through an arbitration process; (2) the plan sponsor makes an election by the otherwise appli- cable deadline that is contingent on the res- olution of the arbitration; and (3) the reso- lution is to not make an election, then the IRS will automatically approve a request to revoke the election. II. Effect on other guidance Notice 2009–31 is hereby modified. Drafting information The principal author of this notice is Diane S. Bloom of the Employee Plans, Tax Exempt and Government Entities Division. For further information re- garding this notice, please contact the Employee Plans taxpayer assistance an- swering service at 1–877–829–5500 (a toll-free number) or e-mail Ms. Bloom at RetirementPlanQuestions@irs.gov. 26 CFR 1.601–201: Rulings and determination let- ters. (Also: Part l, §§ 860, 7502; 1.860–2, 301.7502–1.) Rev. Proc. 2009–28 SECTION 1. PURPOSE This revenue procedure sets forth the circumstances under which the filing of Form 8927,“Determination Under Sec- tion 860(e)(4) by a Qualified Investment Entity,”is treated as a “determination” for purposes of § 860(e) of the Internal Rev- enue Code (Code). SECTION 2. BACKGROUND .01 Section 860 of the Code and the In- come Tax Regulations (Regulations) there- under (together, “the Deficiency Dividend Procedures”) allow a regulated investment company (RIC) or a real estate investment trust (REIT) to be relieved from the pay- ment of a deficiency in (or to be allowed a credit or refund of) certain taxes. .02 To effect this relief, the Deficiency Dividend Procedures allow an additional deduction for dividend distributions that meet the requirements of § 860 and § 1.860–2 of the Regulations (“deficiency dividends”). The deduction is allowed in computing the deduction for dividends paid for the taxable year for which the deficiency is determined. .03ARICorREITisallowedade- duction for a deficiency dividend only if, among other things, there is a de- termination (as defined in § 860(e) and § 1.860–2(b)(1) of the Regulations) that results in an adjustment (as defined in § 860(d)(1) or 860(d)(2)) for the taxable year for which the deficiency dividend is paid. .04 Under the Deficiency Dividend Pro- cedures, the date of the determination con- trols the timeliness of certain acts that the RIC or REIT must perform. (See itali- cized phrases in Section 2.04 through 2.06 of this revenue procedure.) For exam- ple, § 860(f)(1) provides generally that, for purposes of § 860, the term “deficiency dividends” means a distribution of prop- erty that— •Is made by a RIC or REIT; •Is madeon or after the date of the de- terminationand before the filing of a claim under § 860(g); and •Would have been includible in the computation of the deduction under § 561 for dividends paid for the taxable year with respect to which the liability for tax resulting from the determina- tion exists, if that distribution had been made during that taxable year. .05 Section 860(f)(1) provides further that no distribution of property shall be considered as deficiency dividends for pur- poses of § 860(a) unless the property isdis- tributed within 90 days after the determi- nationand unless a claim for a deficiency dividend deduction with respect to the dis- tribution is filed pursuant to § 860(g). .06 Section 860(g) provides that no deficiency dividend deduction shall be allowed under § 860(a) unless (under reg- ulations prescribed by the Secretary) a claim therefor is filedwithin 120 days after the date of the determination. Under § 1.860–2(a)(2) of the Regulations, the claim that § 860(g) requires is filed on Form 976,“Claim for Deficiency Divi- dends Deductions by a Personal Holding Company, Regulated Investment Com- pany, or Real Estate Investment Trust.” May 18, 200910112009–20 I.R.B. .07 In addition, under § 860(h), certain rules regarding the suspension of the run- ning of the statute of limitations and stay of collection are determined by reference to the date of the determination. Thus, the date of the determination is a critical date not only for RICs and REITs attempting to comply with the requirements of the Deficiency Dividend Procedures but also for representatives of the Internal Revenue Service (Service) attempting to enforce the provisions of the Deficiency Dividend Procedures. .08 The American Jobs Creation Act of 2004, Pub. L. No. 108–357, 118 Stat. 1418 (AJCA), § 243(f)(5), added § 860(e)(4) to the Code. The addition expanded the meaning of the term “de- termination” for purposes of § 860. As amended, the term includes not only the determinations described in pre-existing §§ 860(e)(1), (e)(2), and (e)(3) but also RIC and REIT self-determinations (“a statement by the taxpayer attached to its amendment or supplement to a return of tax for the relevant tax year”). Section 243(g)(4)(E) of the AJCA provides that § 860(e)(4) applies to statements filed af- ter October 22, 2004. .09 The Deficiency Dividend Pro- cedures provide no rules regarding the date of determination for a RIC or REIT self-determination under § 860(e)(4), the contents of the statement that § 860(e)(4) requires, or the manner in which the tax- payer may attach the statement to its amendment or supplement to a return of tax for the relevant tax year. Moreover, the legislative history to § 860(e)(4) provides no specific guidance on these issues. .10 Section 7502(a) prescribes a timely- mailing/timely-filing rule for any return, claim, statement, or other document that is required to be filed within a prescribed pe- riod or on or before a prescribed date under authority of any provision of the internal revenue laws but that is received after the prescribed time. .11 Congress appears to have expected that statements of self-determination under § 860(e)(4) would be filed within a reason- able time after the taxpayer discovers the existence of a deficiency. For purposes of § 7502, however, that expectation is not a requirement that the statement be filed “within a prescribed period or on or be- fore a prescribed date.” Nevertheless, for purposes of establishing the date of deter- mination under § 860(e)(4), Section 4 of this revenue procedure uses certain princi- ples contained in § 7502 and the regula- tions thereunder. .12 Section 7502(a) and § 301.7502–1 of the Procedure and Administration Reg- ulations generally provide that if a docu- ment is delivered by the United States mail after the due date in a postage prepaid, properly addressed envelope, then the date of the United States postmark is deemed to be the date of delivery if the date of the postmark is on or before the due date. .13Section7502(c)and § 301.7502–1(c)(2) and (e) of the Pro- cedure and Administration Regulations provide the rules applicable to registered and certified mail. If a document or payment is sent by registered or certified mail, the date of registration, or the date of the postmark on the certified mail sender’s receipt, is treated as the postmark date. If a document (but not a payment) is sent by registered or certified mail, proof that the document was properly registered or that a postmarked certified mail sender’s receipt was properly issued and that the envelope was properly addressed to the agency, officer, or office constitutesprima facieevidence that the document was delivered to the agency, officer, or office. .14 Section 7502(f) authorizes the Sec- retary to designate certain private delivery services (PDSs) for purposes of § 7502. If the Secretary so designates a PDS, ref- erences in § 7502 to the U.S. mail are treated as including the designated PDS, and references to a postmark are treated as including the analogous date that is recorded or marked by the designated PDS (see§ 7502(f)(2)(C)).See alsoRev. Proc. 97–19, 1997–1 C.B. 644,modified,Notice 2002–62, 2002–2 C.B. 574,modified,No- tice 2004–83, 2004–2 C.B. 1030. Notice 2004–83, 2004–2 C.B. 1030, modifies Notice 2002–62, 2002–2 C.B. 574, and updates the list of PDSs that have been designated for purposes of § 7502. Notice 97–26, 1997–1 C.B. 413,modified,No- tice 2002–62, 2002–2 C.B. 574, provides special rules to determine the date that is treated as the postmark date for purposes of § 7502 when a designated PDS is used. SECTION 3. SCOPE This revenue procedure applies to RICs and REITs that seek to make a determina- tion under § 860(e)(4). SECTION 4. PROCEDURE .01Determination. (1) In general, if a RIC or REIT (the tax- payer) properly completes Form 8927, and files Form 8927 with the Service, in ac- cordance with the applicable instructions, then that form will be treated for purposes of § 860(e)(4) as “a statement by the tax- payer attached to its amendment or supple- ment to a return of tax for the relevant tax year.” As such, it qualifies as a “determi- nation” for purposes of § 860(e). (2) The taxpayer’s Form 8927 is a “de- termination” for purposes of § 860(e) only if it is delivered to the Service. Taxpay- ers are advised, therefore, to request a re- turn receipt or other comparable evidence of actual receipt by the Service to estab- lish that the Form 8927 was delivered to the Service. (3) If the taxpayer does not have proof of actual delivery to the Service,prima fa- cieevidence that the Form 8927 was de- livered to the Service is the same as evi- dence that would beprima facieevidence of delivery of a document under the prin- ciples of § 7502(c) and § 301.7502–1(e) of the Procedure and Administration Regula- tions. .02Date of the Determination. (1) If Form 8927 is sent by U.S. mail or by proper use of a PDS that the Secre- tary has designated for purposes of § 7502, then the date of the determination is the postmark date determined using the prin- ciples of § 301.7502–1(c) of the Proce- dure and Administration Regulations and any applicable guidance regarding desig- nated PDSs (without regard to any par- ticular “prescribed time”). Thus, for ex- ample, if the taxpayer sends Form 8927 by U.S. registered mail, the date of the determination for purposes of § 860(e)(4) is the date of registration of the envelope containing Form 8927. If the taxpayer sends Form 8927 by U.S. certified mail and the sender’s receipt is postmarked by the postal employee to whom Form 8927 was presented, the date of the determina- tion for purposes § 860(e)(4) is the date of the U.S. postmark on the sender’s re- 2009–20 I.R.B.1012May 18, 2009 ceipt. If the taxpayer sends Form 8927 by proper use of a PDS that the secretary has designated for purposes of § 7502, then the date of the determination for purposes of § 860(e)(4) is the date that would be treated as the postmark date for purposes of § 7502. (2) If the taxpayer files Form 8927 with the Service by means other than U.S. mail or a PDS that the Secretary has designated for purposes of § 7502, then the date of the determination is the date the Form 8927 is received by the Service. .03Deficiency dividend. Even though there may have been a determination within the meaning of § 860(e)(4), a distri- bution does not satisfy § 860(f)(1) unless it is made on or after the date of the determi- nation(asestablishedbySection4.02of this Revenue Procedure) and on or before the date that is 90 days after the date of the determination (as so established). SECTION 5. EFFECTIVE DATE This revenue procedure is effective July 1, 2009. DRAFTING INFORMATION The principal author of this revenue procedure is Roger E. Wade of the Office of Associate Chief Counsel (Financial Institutions & Products). For further infor- mation regarding this revenue procedure, contact Roger E. Wade at (202) 622–6927 (not a toll-free call). May 18, 200910132009–20 I.R.B. Part IV. Items o fGeneralInterest Notice of Prop osed Rulemaking by Cross-Refere nce to Temporary Re gulations Use of Actuar ial Tables in Valuing Annu ities, Interests for Life or T erms of Years, and Remainder o rReversionary Interests REG–107845–08 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Not ice of proposed rulemaking by cross-r eference to temporary regula- tions. SUMMARY: These proposed regulations relate to the use of actuarial tables in valu- ing annuities, interests for life or terms of years, and remainder or reversionary in- terests. These regulations will affect the valuation ofinter vivosand testamentary transfers of interest dependent on one or more measuring lives. These regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuar- ial tables to reflect the most recent mortal- ity experience available. The text of the temporary regulations (T.D. 9448) in this issue of the Bulletin also serves as the text of these proposed regulations. DATES: Written and electronic comments and requests for a public hearing must be received by August 5, 2009. ADDRES SES: Send submissions to CC:PA: LPD:PR (REG–107845–08), room 5205, I nternal Revenue Service, PO Box 7604, B en Franklin Station, Washing- ton, DC 20044. Submissions may be hand- delivered Monday through Friday betwe en the hours of 8 a.m. and 4 p.m. to: CC :PA:LPD:PR (REG–107845–08), Couri er’s Desk, Internal Revenue Service, 1111 C onstitution Avenue, NW, Washing- ton, D C, or sent via the Federal eRule- maki ng Portal atwww.regulations.gov (REG –107845–08). FOR FURTHER IN FORMATION CONTACT: Maye rR.Samuels, (202)622–309 0;concern- ing submissio ns of comments, Richar.A.Hur st@irscounsel.treas.gov, (202) 622–71 80 (not toll-free numbers). SUPPLEMENTA RY INFORMATION: Background Temporary re gulations in this issue of the Bullet in amend Income Tax Reg- ulations (26 CFR part 1) under sections 642(c)(5) a nd 664, Estate Tax Regulations (26 CFR part 20) under section 2031, and Gift Tax Reg ulations (26 CFR part 25) un- der section 2512. These regulations revise actuarial t ables used for the valuation of partial in terests in property under section 7520 to ref lect the mortality experience basedonth e2000UnitedStatescensus, the most re cent mortality experience avail- able. The text of those temporary regulations also serve s as the text of these proposed regulati ons. The preamble to the tem- porary re gulations explains the temporary regulati ons. Special A nalyses It has bee n determined that this notice of propos ed rulemaking is not a significant regulat ory action as defined in EO 12866. Therefo re, a regulatory assessment is not require d. It also has been determined that sec tion 553(b) of the Administrative Procedu re Act (5 U.S.C. chapter 5) does no t apply to these regulations, and becaus e these regulations do not impose a collec tion of information requirement on small e ntities, the Regulatory Flexibility Act (5 U .S.C. chapter 6) does not apply . Pursuant to section 7805(f) of the Inter nal Revenue Code this regulation has be en submitted to the Chief Counsel for Ad vocacy of the Small Business Admin istration for comment on its impact on sma ll business. Comme nts and Requests for a Public Hear ing Befo re these proposed regulations are adop ted as final regulations, consideration will be given t o any written (a signed origi- nal and eight ( 8) copies) or electronic com- ments that are submitted timely to the IRS. The IRS and the Treasury Department also request comme nts on the clarity of the pro- posed rules a nd how they can be made eas- ier to unders tand. All comments will be available fo r public inspection and copy- ing. A public hearing will be scheduled if requeste dinwritingbyanypersonthat timely subm its written comments. If a public hear ing is scheduled, notice of the date, time, and place for the public hearing will be pub lished in theFederal Register. ***** Drafting Information The princi pal author of these regula- tions is M ayer R. Samuels, Office of the Associat e Chief Counsel (Passthroughs and Speci al Industries), IRS. However, other per sonnel from the IRS and Treasury Departm ent participated in their develop- ment. Proposed Amendments to the Regulations Accordingly, 26 CFR part 1 is proposed to be amended as follows: PART 1— INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.170A–12 is amended as follows: 1. Paragraphs (b)(2) and (b)(3) are re- vised. 2. Paragraph (f) is added. The revisions and addition read as fol- lows: §1.170A–12 Valuation of a remainder interest in real property for contributions made after July 31, 1969. ***** (b) * * * (2) [T he text of this proposed para- graph (b)(2) is the same as the text of §1.17 0A–12T(b)(2) published elsewhere in thi s issue of the Bulletin]. 2009–20 I.R.B.1014May 18, 2009 (3) [The text of this proposed para- graph (b)(3) is the same as the text of §1.170A–12T(b)(3) published elsewhere in this issue of the Bulletin]. ***** (f) [The text of this proposed para- graph (f) is the same as the text of §1.170A–12T(f) published elsewhere in this issue of the Bulletin]. ***** Par. 3. Section 1.642(c)–6 is amended by revising paragraphs (d), (e) and (f) to read as follows: §1.642(c)–6 Valuation of a remainder interest in property transferred to a pooled income fund. ***** (d) [The text of this proposed para- graph (d) is the same as the text of §1.642(c)–6T(d) published elsewhere in this issue of the Bulletin]. (e) [The text of this proposed para- graph (e) is the same as the text of §1.642(c)–6T(e) published elsewhere in this issue of the Bulletin]. (f) [The text of this proposed para- graph (f) is the same as the text of §1.642(c)–6T(f) published elsewhere in this issue of the Bulletin]. Par. 4. Section 1.664–4 is amended by revising paragraphs (a)(1), (d), (e)(1), (e)(2), (e)(5), (e)(7), and (f) to read as fol- lows: §1.664–4 Calculation of the fair market value of the remainder interest in a charitable remainder unitrust. (a) * * * (1) [The text of this proposed para- graph (a)(1) is the same as the text of §1.664–4T(a)(1) published elsewhere in this issue of the Bulletin]. ***** (d) [The text of this proposed paragraph (d) is the same as the text of §1.664–4T(d) published elsewhere in this issue of the Bulletin]. (e)(1) [The text of this proposed para- graph (e)(1) is the same as the text of §1.664–4T(e)(1) published elsewhere in this issue of the Bulletin]. (e)(2) [The text of this proposed para- graph (e)(2) is the same as the text of §1.664–4T(e)(2) published elsewhere in this issue of the Bulletin]. ***** (e)(5) [The text of this proposed para- graph (e)(5) is the same as the text of §1.664–4T(e)(5) published elsewhere in this issue of the Bulletin]. ***** (e)(7) [The text of this proposed para- graph (e)(7) is the same as the text of §1.664–4T(e)(7) published elsewhere in this issue of the Bulletin]. (f) [The text of this proposed paragraph (f) is the same as the text of §1.664–4T(f) published elsewhere in this issue of the Bulletin]. Par. 5. Section 1.7520–1 is amended by revising paragraphs (a)(1), (a)(2), (b)(2), (c)(1), (c)(2) and (d) to read as follows: §1.7520–1 Valuation of annuities, unitrust interest, interests for life or terms of years, and remainder or reversionary interests. (a) (1) [The text of this proposed para- graph (a)(1) is the same as the text of §1.7520–1T(a)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (a)(2) is the same as the text of §1.7520–1T(a)(2) published elsewhere in this issue of the Bulletin]. (b) * * * (2) [The text of this proposed para- graph (b)(2) is the same as the text of §1.7520–1T(b)(2) published elsewhere in this issue of the Bulletin]. (c) * * * (1) [The text of this proposed para- graph (c)(1) is the same as the text of §1.7520–1T(c)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (c)(2) is the same as the text of §1.7520–1T(c)(2) published elsewhere in this issue of the Bulletin]. (d) [The text of this proposed paragraph (d) is the same as the text of §1.7520–1T(d) published elsewhere in this issue of the Bulletin]. PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Par. 6. The authority citation for part 20 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 7. Section 20.2031–7 is amended by revising paragraphs (c), (d)(1), (d)(2), (d)(3), (d)(4), (d)(5), (d)(7), and (e) to read as follows: §20.2031–7 Valuation of annuities, interests for life or term of years , and remainder or reversionary interests. ***** (c) [The text of this proposed para- graph (c) is the same as the text of §20.2031–7T(c) published elsewhere in this issue of the Bulletin]. (d) [The text of this proposed paragraph (d)(1) through (d)(5) is the same as the text of §20.2031–7T(d)(1) through (d)(5) published elsewhere in this issue of the Bulletin]. ***** (7) [The text of this proposed para- graph (d)(7) is the same as the text of §20.2031–7T(d)(7) published elsewhere in this issue of the Bulletin]. (e) [The text of this proposed para- graph (e) is the same as the text of §20.2031–7T(e) published elsewhere in this issue of the Bulletin]. Par. 8. Section 20.2032–1 is amended by revising paragraphs (f)(1) and (h) to read as follows: §20.2032–1 Alternate valuation. ***** (f) * * * (1) [The text of this proposed para- graph (f)(1) is the same as the text of §20.2032–1T(f)(1) published elsewhere in this issue of the Bulletin]. ***** (h) [The text of this proposed para- graph (h) is the same as the text of §20.2032–1T(h) published elsewhere in this issue of the Bulletin]. Par. 9. Section 20.2055–2 is amended by revising paragraphs (e)(3)(iii) and (f)(4) to read as follows: §20.2055–2 Transfers not exclusively for charitable purposes. ***** (e) * * * (3) * * * (iii) [The text of this proposed para- graph (e)(3)(iii) is the same as the text of §20.2055–2T(e)(3)(iii) published else- whereinthisissueoftheBulletin]. ***** May 18, 200910152009–20 I.R.B. (f) * * * (4) [The text of this proposed para- graph (f)(4) is the same as the text of §20.2055–2T(f)(4) published elsewhere in this issue of the Bulletin]. Par.10.Section 20.2056A–4 is amended by revising paragraph (c)(4)(ii)(B) andExample 4in paragraph (d) to read 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) [The text of this proposed para- graph (c)(4)(ii)(B) is the same as the text of §20.2056A–4T(c)(4)(ii)(B) published elsewhere in this issue of the Bulletin]. ***** (d) * * * Example 4. [The text of this proposed paragraph (d),Example 4is the same as the text ofExample 4in §20.2056A–4T(d) published elsewhere in this issue of the Bulletin]. Par. 11. Section 20.7520–1 is amended by revising paragraphs (a)(1), (a)(2), (b)(2), (c)(1), (c)(2) and (d) to read as follows: §20.7520–1 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests. (a)***(1)[Thetextofthisproposed paragraph (a)(1) is the same as the text of §20.7520–1T(a)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (a)(2) is the same as the text of §20.7520–1T(a)(2) published elsewhere in this issue of the Bulletin]. (3) * * * (b) * * * (2) [The text of this proposed para- graph (b)(2) is the same as the text of §20.7520–1T(b)(2) published elsewhere in this issue of the Bulletin]. (1) [The text of this proposed para- graph (c)(1) is the same as the text of §20.7520–1T(c)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (c)(2) is the same as the text of §20.7520–1T(c)(2) published elsewhere in this issue of the Bulletin]. (d) [The text of this proposed para- graph (d) is the same as the text of §20.7520–1T(d) published elsewhere in this issue of the Bulletin]. PART 25—GIFT TAX; GIFTS MADE AFTER DECEMBER 31, 1954 Par. 12. The authority citation for part 25 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 13. Section 25.2512–5 is amended by revising paragraphs (c), (d) and (e) to read as follows: §25.2512–5 Valuation of annuities, unitrust interest, interests for life or term of years, and remainder or reversionary interests. ***** (c) [The text of this proposed para- graph (c) is the same as the text of §25.2512–5T(c) published elsewhere in this issue of the Bulletin]. (d) [The text of this proposed para- graph (d) is the same as the text of §25.2512–5T(d) published elsewhere in this issue of the Bulletin]. (e) [The text of this proposed para- graph (e) is the same as the text of §25.2512–5T(e) published elsewhere in this issue of the Bulletin]. Par. 14. 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) [The text of this proposed para- graph (e) is the same as the text of §25.2522(c)–3T(e) published elsewhere in this issue of the Bulletin]. Par. 15. Section 25.7520–1 is amended by revising paragraphs (a)(1), (a)(2), (b)(2), (c)(1), (c)(2) and (d) to read as follows: §25.7520–1 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests. (a)***(1)[Thetextofthisproposed paragraph (a)(1) is the same as the text of §25.7520–1T(a)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (a)(2) is the same as the text of §25.7520–1T(a)(2) published elsewhere in this issue of the Bulletin]. (3) * * * (b) * * * (2) [The text of this proposed para- graph (b)(2) is the same as the text of §25.7520–1T(b)(2) published elsewhere in this issue of the Bulletin]. (c) * * * (1) [The text of this proposed para- graph (c)(1) is the same as the text of §25.7520–1T(c)(1) published elsewhere in this issue of the Bulletin]. (2) [The text of this proposed para- graph (c)(2) is the same as the text of §25.7520–1T(c)(2) published elsewhere in this issue of the Bulletin]. (d) [The text of this proposed para- graph (d) is the same as the text of §25.7520–1T(d) published elsewhere in this issue of the Bulletin]. Par. 16. Section 25.7520–3 is amended as follows: 1. In paragraph (b)(2)(v),Example 5is revised. 2. Paragraph (b)(4) is revised. 3. Paragraph (c) is revised. The revised text reads as follows: §25.7520–3 Limitation on the application of section 7520. ***** (b) * * * (2) * * * (v) * * * Example 5. [The text of this proposed para- graph (b)(2)(v),Example 5is the same as the text of §25.7520–3T(b)(2)(v),Example 5, published else- where in this issue of the Bulletin]. ***** (b)(4) [The text of this proposed para- graph (b)(4) is the same as the text of §25.7520–3T(b)(4) published elsewhere in this issue of the Bulletin]. ***** (c) [The text of this proposed para- graph (c) is the same as the text of §25.7520–3T(c) published elsewhere in this issue of the Bulletin]. LindaE.Stiff, Deputy Commissioner for Services and Enforcement. 2009–20 I.R.B.1016May 18, 2009 (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. 21519) Notice of Proposed Rulemaking Section 2036—Graduated Retained Interests REG–119532–08 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Notice of proposed rulemaking. SUMMARY: This document contains pro- posed regulations that provide guidance on the portion of trust property includible in the grantor’s gross estate if the grantor has retained the use of the property, the right to an annuity, unitrust, graduated re- tained interest, or other payment from such property for life, for any period not ascer- tainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death. The proposed regulations will affect estates that file Form 706,United States Estate (and Generation-Skipping Transfer) Tax Return. DATES: Written or electronic comments and requests for a public hearing must be received by June 1, 2009. ADDRESSES: Send submissions to: CC:PA:LPD:PR (REG–119532–08), In- ternal Revenue Service, Room 5203, PO Box 7604, Ben Franklin Station, Wash- ington, DC 20044. Submissions may be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (REG–119532–08), Courier’s Desk, Internal Revenue Ser- vice, 1111 Constitution Avenue NW, Washington, DC 20224; or sent elec- tronically via the Federal eRulemaking Portal athttp://www.regulations.gov(IRS REG–119532–08). FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations, Theresa M. Melchiorre, at (202) 622–3090;concerning submissions of comments or to request a hearing, Richard A. Hurst at Richard.A.Hurst @irscounsel.treas.govor (202) 622–7180 (not toll-free numbers). SUPPLEMENTARY INFORMATION: Background On June 7, 2007, proposed regula- tions (REG–119097–05, 2007–1 C.B. 74) were published in theFederal Regis- ter[72 FR 31487] providing guidance on the portion of trust corpus properly includible in a grantor’s gross estate under sections 2036 and 2039. The IRS and Treasury Department determined that certain comments received in response to the proposed regulations should be addressed in a separate notice of proposed rulemaking, instead of in the final regulations published on July 14, 2008 [73 FR 40173], as T.D. 9414, 2008–35 I.R.B. 454. Accordingly, this notice of proposed rulemaking proposes additional changes to the regulations in response to those comments. Theproposedregulations (REG–119097–05) addressed the amount includible in the gross estate under sec- tions 2036 and 2039 if the grantor retains the right to receive an annuity, unitrust, or other payment from a trust for life, for any period not ascertainable without reference to the grantor’s death, or for a period that does not in fact end before the grantor’s death. The trusts that were the subject of the proposed regulations included grantor retained interest trusts (GRTs), such as grantor retained income trusts (GRITs), grantor retained annuity trusts (GRATs) and grantor retained unitrusts (GRUTs) described in section 2702, whether or not the grantor’s retained interest was a “qualified interest” under section 2702(b), as well as other trust forms, including charitable remainder trusts (CRTs), such as charitable remainder unitrusts (CRUTs) and charitable remainder annuity trusts (CRATs) described in section 664 whether or not the trust met the qualifications of section 664(d)(1), (2), or (3). The proposed regulations incorporated the methodology provided in Rev. Rul. 76–273, 1976–2 C.B. 268, and Rev. Rul. 82–105, 1982–1 C.B. 133. See §601.601(d)(2)(ii)(b). Under this method- ology, the portion of the corpus of a GRT or a CRT includible in the decedent’s gross estate under section 2036 is that portion of the trust corpus necessary to generate a return sufficient to pay the decedent’s retained annuity, unitrust, or other payment. One commentator suggested that the regulations address the portion of trust cor- pus of a GRAT includible in the grantor’s gross estate under section 2036 if the deceased grantor retains an interest de- scribed in §25.2702–3(b)(1)(ii)(A); that is, the annuity interest retained by the grantor increases annually during the term of the trust (a graduated retained interest). The commentator suggested two possible methods for determining the portion of GRAT corpus includible in the grantor’s gross estate if the grantor dies during the term of such a GRAT. Another commentator questioned the result in the example contained in §20.2036–1(c)(1)(ii) of the proposed reg- ulations. This example considered the situation where the decedent (D) creates an irrevocableinter vivostrust, under the terms of which all trust income is to be paid to D and E, D’s spouse, in equal shares during their joint lives and, on the death of the first to die of D and E, all trustincomeistobepaidtothesurvivor. On the death of the survivor of D and E, the remainder is to be paid to another individual, F. D dies survived by E. The example concludes that, because D re- tained the right to receive 50 percent of the trust income for a period that did not in fact end before D’sdeath, 50 percent of the trust’s corpus is includible in D’s gross estate under section 2036. The ex- ample also concludes that, if instead E had predeceased D, D would have died while entitled to all of the income from the trust, so that the entire trust corpus would have been includible in D’s gross estate under section 2036. The commentator noted that, because E is identified as D’s spouse, the exam- ple unnecessarily raises issues under sec- tion 2523 (gift tax marital deduction). In addition, the commentator opined that, un- der the facts presented, D has retained the right to receive one-half of trust income during the joint lives of D and E, and the right to receive 100 percent of the trust in- come if D survives E. Thus, 50 percent of the trust corpus is includible in D’s gross estate by virtue of D’s retained right to re- ceive 50 percent of the trust income during D’s life, and the remaining 50 percent of May 18, 200910172009–20 I.R.B. the trust corpus (reduced by the actuarial value of E’s income interest) is includible in D’s gross estate under section 2036 by virtue of D’s retained right to receive all of the trust income provided D survives E. Explanation of Provisions In response to the comments, these pro- posed regulations provide the method to be used to determine the portion of trust cor- pus includible in the grantor’s gross estate if the grantor reserves a graduated retained interest in a trust. This method applies to graduated retained interests in property whether or not the property is held in trust. The portion of the corpus of a GRT or a CRT includible in the decedent’s gross estate under section 2036 is that portion of the trust corpus necessary to generate a return sufficient to pay the decedent’s re- tained annuity, unitrust, or other payment. Consistent with this approach, the pro- posed methodology measures the amount of corpus needed to generate sufficient in- come to produce the payments that would have been due even after the decedent’s death, as if the decedent had survived and continued to receive the retained interest. Thus, under the proposed methodology, the amount of corpus necessary to produce the retained graduated interest is the sum of the following amounts: (1) the amount of corpus required to generate sufficient income to pay, without reducing or invad- ing principal, the annual amount payable to the decedent at the decedent’s death cal- culated pursuant to §20.2036–1(c)(2)(i); and (2) for each succeeding year of the trust, the amount of corpus required to generate sufficient income to pay, with- out reducing or invading principal, the increase (if any) in the annuity, unitrust, or other payment for that year, deferred until the beginning date of that increase. The formula to be applied in calculating the corpus for each such succeeding year of the trust is the product of two factors: the first is the result of dividing the peri- odic addition (adjusted for payments made more frequently thanannually, if applica- ble, and for payments due at the beginning, rather than the end, of a payment period (See Table K or J of §20.2031–7(d)(6)) by the section 7520 rate (periodic addi- tion / rate); and the second is 1 divided by the sum of 1 and the section 7520 rate raised to the T power (1 / (1 + rate)^T). For purposes of this formula, T is the time (expressed in years or a portion of a year) between the date of the decedent’s death and the first day of the trust’s first year for which the periodic addition is payable. The periodic addition for each year after the year in which the decedent’s death occurs is the amount (if any) by which the annuity, unitrust, or other payment that would have been payable for that year (if the decedent had survived) exceeds the total amount of payments for the year im- mediately preceding that year, provided that payments increase (and do not ever decrease). This formula would be: (Periodic Addition) x (Adjustment Factor)X1 Section 7520 Rate(1+ Section 7520 Rate) T Where adjustment factor, if applicable, is the factor for payments made more frequently than annually, and for pay- ments due at the beginning, rather than the end, of a calendar period (See Ta- ble K or J of §20.2031–7(d)(6)) and T equals the time period in years from the date of death through the last day of the trust year immediately before the year for which the periodic addition is first payable. The proposed regulations also add §20.2036–1(c)(2)(iii),Example 7, illus- trating this computation. In addition, in response to the com- ments, §20.2036–1(c)(1)(ii),Example 1 (which was reserved in the final regu- lations REG–119097–05 (T.D. 9414)) is added. In this example, trust income is payable to D and C, D’s child, in equal shares during their joint lives and, on the death of the first to die of D and C, all trust income is to be paid to the survivor. The example concludes that, if D dies before C, 100 percent of the trust corpus, reduced bythepresentvalueofC’slifeinterest, is includible in D’s gross estate under section 2036. Fifty percent of the trust corpus is includible in D’s gross estate because D retained the right to receive 50 percent of the trust’s income for life. The remaining 50 percent of the trust corpus (less the present value of C’s outstanding life interest) is includible in D’s gross es- tate because at D’s death D retained the right to receive all of the trust income if D survived C. This result is consistent with §20.2036–1(b)(1)(ii). Finally,§20.2036–1(b)(1)(ii) is amended to clarify the computation of the includible amount if the decedent retained the right to receive an annuity or other payment (rather than income) after the death of the current recipient of that in- terest. Example 1 of §20.2036–1(c)(1)(ii) has been expanded to provide an illustra- tion of this computation. In general, under this computation, the amount includible is the portion of the date of death value of the trust corpus required to produce sufficient income to satisfy the annuity or other payment the decedent would have been entitled to receive if the decedent had survived the current recipient, reduced by thepresentvalueofthecurrent recipient’s interest. However, the amount includible shall not be less than the amount of corpus required to produce sufficient income to satisfy the annuity or other payment the decedent was entitled to receive for the trust’s year in which the decedent’s death occurred. In no event, however, shall the amount includible exceed the value of the trust corpus on the date of death. Proposed Effective Date All of §20.2036–1(b)(1)(ii), the in- troductory text of §20.2036–1(c)(1)(ii), Example 1of §20.2036–1(c)(1)(ii), all of §20.2036–1(c)(2)(ii), andExample 7 of §20.2036–1(c)(2)(iii) are applicable to estates of decedents dying on or after the date of publication in theFederal Regis- terof the Treasury decision adopting these rules as final regulations. Special Analyses It has been determined that this notice of proposed rulemaking is not a significant regulatory action as defined in Executive Order 12866. Therefore, a regulatory as- sessment is not required. It also has been 2009–20 I.R.B.1018May 18, 2009 determined that section 553(b) of the Ad- ministrative Procedure Act (5 U.S.C. chap- ter 5) does not apply to these regulations and, because these regulations do not im- pose on small entities a collection of infor- mation requirement, the Regulatory Flex- ibility Act (5 U.S.C. chapter 6) does not apply. Pursuant to section 7805(f) of the Internal Revenue Code, this regulation has been submitted to the Chief Counsel for Advocacy of the Small Business Adminis- tration for comment on its impact on small business. Comments and Requests for a Public Hearing Before these proposed regulations are adopted as final regulations, consideration will be given to any written (a signed origi- nal and eight (8) copies) or electronic com- ments that are submitted timely to the IRS. The IRS and the Treasury Department also request comments on the clarity of the pro- posed regulations and how they may be made easier to understand. All comments will be available for public inspection and copying. A public hearing may be sched- uled if requested in writing by any person that timely submits written comments to the IRS. If a public hearing is scheduled, notice of the date, time, and place for the hearing will be published in theFederal Register. Drafting Information The principal author of these regula- tionsisTheresaM.Melchiorre,Officeof Associate Chief Counsel (Passthroughs and Special Industries), IRS. ***** Proposed Amendments to the Regulations Accordingly, 26 CFR part 20 is pro- posedtobeamendedasfollows: PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954 Paragraph 1. The authority citation for part 20 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 20.2036–1 is amended by: 1. Revising paragraph (b)(1)(ii) and paragraph (c)(1)(ii) introductory text. 2. Adding paragraphs (c)(1)(ii)Ex- ample 1, (c)(2)(ii), (c)(2)(iii)Example 7, and two sentences at the end of paragraph (c)(3). The revisions and additions read as fol- lows: §20.2036–1 Transfers with retained life estate. ***** (b)***(1)*** (ii) A decedent reserved the right to re- ceive the income, annuity, or other pay- ment from transferred property after the death of another person who was in fact enjoying the income, annuity, or other pay- ment at the time of the decedent’s death. In such a case, the amount to be included in the decedent’s gross estate under this sec- tion does not include the value of the out- standing interest of the other person. If the other person predeceased the decedent, the reservation by the decedent may be con- sidered to be either for life, or for a period which does not in fact end before death. If the decedent retained the right to receive an annuity or other payment (rather than income) after the death of the current re- cipient of that interest, then the amount in- cludible in the decedent’s gross estate un- der section 2036 is the amount of trust cor- pus required to produce sufficient income to satisfy the entire annuity or other pay- ment the decedent would have been enti- tled to receive if the decedent had survived the current recipient (thus, also including the portion of that entire amount payable to the decedent before the current recipient’s death), reduced by the present value of the current recipient’s interest. However, the amount includible shall not be less than the amount of corpus required to produce sufficient income to satisfy the annuity or other payment the decedent was entitled, at the time of the decedent’s death, to receive for each year. In no event, however, shall the amount includible exceed the value of the trust corpus on the date of death. The following steps implement this computa- tion. (A) Step 1: Determine the fair market value of the trust corpus on the date of death. (B) Step 2: Determine, in accordance with paragraph (c)(2)(i) of this section, the amount of corpus required to generate suf- ficient income to pay the annuity, unitrust, or other payment (determined on the date of the decedent’s death) payable to the decedent for the trust year in which the decedent’s death occurred. (C) Step 3: Determine, in accordance with paragraph (c)(2)(i) of this section, the amount of corpus required to generate suf- ficient income to pay the annuity, unitrust, or other payment that the decedent would have been entitled to receive for each trust year if the decedent had survived the cur- rent recipient. (D) Step 4: Determine the present value of the current recipient’s annuity, unitrust, or other payment. (E) Step 5: Reduce the amount deter- mined in Step 3 by the amount determined in Step 4, but not to below the amount de- termined in Step 2. (F) Step 6: The amount includible in the decedent’s gross estate under section 2036 is the lesser of the amounts determined in Step 5 and Step 1. ***** (c)***(1)*** (ii)Examples. The application of para- graphs (b)(1)(ii) and (c)(1)(i) of this sec- tion is illustrated in the following exam- ples: Example 1. (i) In 2001, Decedent (D) creates an irrevocableinter vivostrust. The terms of the trust provide that all of the trust income is to be paid to D and C, D’s child, in equal shares during their joint lives and, on the death of the first to die of D and C, all of the trust income is to be paid to the survivor. On the death of the survivor of D and C, the remainder is to be paid to another individual, F. In 2009, D dies survived by C. Fifty percent of the value of the trust corpus is includible in D’s gross estate under section 2036(a)(1) because, under the terms of the trust, D re- tained the right to receive one-half of the trust income for D’s life. In addition, the value of the remaining 50 percent of the trust corpus, less the present value of C’s outstanding life estate, also is includible in D’s gross estate under section 2036(a)(1), because D re- tained the right to receive all of the trust income for such time as D survived C. If C had predeceased D, then 100 percent of the trust corpus would have been includible in D’s gross estate. (ii) Assume the same facts as above, except that the trust provides that, rather than all the income, an annuity of $10,000 per year is to be paid to D and C in equal shares during their joint lives and, on the death of the first to die of D and C, the entire $10,000 an- nuityistobepaidtothesurvivorforlife. OnD’s date of death, the fair market value of the trust is $120,000 and the section 7520 rate is 7 percent. At the date of death, the amount of trust corpus needed to produce D’s annuity interest ($5,000 per year) is $71,429 ($5,000/.07). In addition, assume the present value of C’s right to receive $5,000 annually for the May 18, 200910192009–20 I.R.B. remainder of C’s life is $40,000. The portion of the trust corpus includible in D’s gross estate under sec- tion 2036(a)(1) is $102,857, determined as follows: (A) Step 1: Fair market value of corpus. $120,000 (B) Step 2: Corpus required to produce D’s date of death annuity ($5,000/.07). $71,429 (C) Step 3: Corpus required to produce D’s annuity if D had survived C ($10,000/.07). $142,857 (D) Step 4: Present value of C’s interest. $40,000 (E) Step 5: The amount determined in Step 3 reduced by the amount determined in Step 4, but not to below the amount determined in Step 2 ($142,857 - $40,000, but not less than $71,429). $102,857 (F) Step 6: The lesser of the amounts determined in Steps 5 and 1 ($102,857 or $120,000). $102,857 ***** (2)***(i)*** (ii)Graduated retained interests—(A) In general. For purposes of this section, a graduated retained interestis the grantor’s reservation of a right to receive an annuity, unitrust, or other payment as described in paragraph (c)(2)(i) of this section, payable at least annually, that increases (but does not decrease) over a period of time, not more often than annually. (B)Other definitions—(1)Base amount.Thebase amountis the amount of corpus required to generate the annuity, unitrust, or other payment payable for the trust year in which the decedent’s death occurs. See paragraph (c)(2)(i) of this sec- tion for the calculation of the base amount. (2)Periodic addition.Theperiodic ad- ditionin a graduated retained interest for each year after the year in which dece- dent’s death occurs is the amount (if any) by which the annuity, unitrust, or other payment that would have been payable for that year if the decedent had survived ex- ceeds the total amount of payments for the year immediately preceding that year. For example, assume the trust instrument pro- vides that the grantor is to receive an an- nual annuity payable to the grantor or his estate for a 5-year term. The initial an- nual payment is $100,000, and each suc- ceeding annual payment is to be 120 per- cent of the amount payable for the preced- ingyear.Assumingthegrantordiesinthe second year of the trust (whether before or after the due date of the second annual pay- ment), the periodic additions for years 3, 4, and 5 of the trust are as follows: (1) Annual P ayment (2) Prior Y earPayment (1 - 2) Periodic A ddition Year 3144,000120,00024,000 Year 4172,800144,00028,800 Year 5 207,360172,800 34,560 (3)Corpus amount. For each trust year in which a periodic addition occurs (increase year), thecorpus amountis the amount of trust corpus which, starting from the decedent’s date of death, is nec- essary to generate an amount of income sufficient to pay the periodic addition, beginning in the increase year and con- tinuing in perpetuity, without reducing or invading principal. For each year with a periodic addition, the corpus amount re- quired as of the date of death is the product of two factors: the first is the result of dividing the periodic addition (adjusted for payments made more frequently than annually, if applicable, and for payments due at the beginning, rather than the end, of a payment period (see Table K or J of §20.2031–7(d)(6)) by the section 7520 rate (periodic addition / rate); and the sec- ond is 1 divided by the sum of 1 and the section 7520 rate raised to the T power (1 / (1 + rate)^T). (i) That formula is: (Periodic Addition) x (Adjustment Factor)X1 Section 7520 Rate (1+ Section 7520 Rate)(1+ Section 7520 Rate) T (ii) Where adjustment factor, if appli- cable, is the factor for payments made more frequently than annually and for payments due at the beginning, rather than the end, of a calendar period (See Table K or J of §20.2031–7(d)(6)) and T equals the time period in years from the date of death through the last day of the trust year immediately before the year for which the periodic addition is first payable. (C)Amount includible. The amount in- cludible in the gross estate in the case of a graduated retained interest is the sum of the base amount and the corpus amount for each year for which a periodic addition is first payable. The sum of these amounts represents the amount of trust principal that would be necessary to generate the an- nual payments that would have been paid to the decedent if the decedent had sur- vived and had continued to receive the re- 2009–20 I.R.B.1020May 18, 2009 served graduated retained interest. The amount of trust corpus includible in a dece- dent’s gross estate under this section, how- ever, shall not exceed the fair market value of the trust corpus on the decedent’s date of death. The provisions of this section also apply to graduated retained interests in transferred property not held in trust. (iii) * * * ***** Example 7. (i) On November 1, year N, D trans- fers assets valued at $2,000,000 to a GRAT. Under the terms of the GRAT, the trustee is to pay to D an annu- ity for a 5-year term that qualifies as a qualified inter- est described in section 2702(b). The annuity amount is to be paid annually at the end of each trust year, on October 31st. The first annual payment is to be $100,000. Each succeeding payment is to be 120 per- cent of the amount paid in the preceding year. Income not distributed in any year is to be added to principal. If D dies during the 5-year term, the payments are to be made to D’s estate for the balance of the GRAT term. At the end of the 5-year term, the trust is to ter- minate and the corpus is to be distributed to C, D’s child. D dies on January 31st of the third year of the GRAT term. On the date of D’s death, the value of the trust corpus is $3,200,000 and the section 7520 inter- est rate is 6.8 percent. D’s executor does not elect to value the gross estate as of the alternate valuation date. (ii) The amount includible in D’s gross estate under section 2036(a)(1) is deter- mined and illustrated as follows using the methodology contained in paragraph (c)(2)(ii)(C) of this section: ABCDEFG RequiredDeferralPresentCorpus AnnualPrincipal:Period:ValueAmount GRATAnnuityPeriodicC x Adj. Factor /Death toFactor:At Death: YearPaymentAddition0.068GRAT Year1/(1+.068)^ED x F 3144,000n/a2,117,647n/an/a2,117,647 4172,80028,800 423,5290.7479450.951985 403,193 5 207,360 34,560508,2351.747945 0.891372 453,026 Total:2,973,866 (iii) An illustration of the amount of trust corpus (as of the decedent’s death) necessary to produce the scheduled pay- mentsisasfollows: Year 3Year 4Year 5Includible Amount Additional Annuity $34,560 Deferral Period $453,026$453,026 Additional Annuity $28,800 Deferral Period $403,193$403,193 Annuity in Year of Death $144,000$2,117,647$ 2,117,647 Total amount included in gross estate (sum) $2,973,866 (iv) A total corpus amount (as de- fined in paragraph (c)(2)(ii)(B)(3)ofthis section) of $2,973,866 constitutes the principal required as of D’s date of death to produce (without reducing or invad- ing principal) the annual payments that D would have received if D had survived and continued to receive the retained annuity. Therefore, $2,973,866 of the trust corpus is includible in D’s gross estate under sec- tion 2036(a)(1). The remaining $226,134 of the trust corpus is not includible in D’s gross estate under section 2036(a)(1). The result would be the same if D’s retained annuity instead had been payable to D for a term of 5 years, or until D’s prior death, at which time the GRAT would have ter- minated and the trust corpus would have become payable to another. (v) If, instead, D’s annuity was to have been paid on a monthly or quarterly ba- sis, then the periodic addition would have to be adjusted as provided in paragraph (c)(2)(ii)(B)(3) of this section. Specifi- cally, in Column D of the Table for years 4 and 5 in this example, the amount of the principal required would be computed by multiplying the periodic addition by the appropriate factor from Table K or J of §20.2036–7(d)(6) before dividing as indicated and computing the amounts in Columns E through G. In addition, Col- umn D in year 3 also would have to be so adjusted. Under the facts presented, sec- tion 2039 does not apply to include any amount in D’s gross estate by reason of this retained interest. See §20.2039–1(e). (3)***Paragraph(b)(1)(ii)ofthissec- tion is applicable to estates of decedents dying on or after the date of publication in theFederal Registerof the Treasury decision adopting these rules as final reg- ulations. The introductory text of para- graph (c)(1)(ii) of this section,Example 1 of paragraph (c)(1)(ii) of this section, all of paragraph (c)(2)(ii) of this section, andEx- ample 7of paragraph (c)(2)(iii) of this sec- tion, are applicable to estates of decedents May 18, 200910212009–20 I.R.B. dying on or after the date of publication in theFederal Registerof the Treasury de- cision adopting these rules as final regula- tions. Linda E. Stiff, Deputy Commissioner for Services and Enforcement. (Filed by the Office of the Federal Register on April 29, 2009, 8:45 a.m., and published in the issue of the Federal Register for April 30, 2009, 74 F.R. 19913) Section 482: Methods To Determine Taxable Income in Connection With a Cost Sharing Arrangement; Correction Announcement 2009–39 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendment. SUMMARY: This document contains corrections to final and temporary regula- tions (T.D. 9441, 2009–7 I.R.B. 460) that were published in theFederal Register on Monday, January 5, 2009 (74 FR 340) providing further guidance and clarifica- tion regarding methods under section 482 to determine taxable income in connection with a cost sharing arrangement in order to address issues that have arisen in ad- ministering the current regulations. The temporary regulations affect domestic and foreign entities that enter into cost sharing arrangements described in the temporary regulations. DATES: This correction is effective March 5, 2009, and is applicable on January 5, 2009. FOR FURTHER INFORMATION CONTACT: Kenneth P. Christman, (202) 435–5265 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final and temporary regulations that are the subject of this document are under sections 367 and 482 of the Internal Revenue Code. Need for Correction As published, final and temporary reg- ulations (T.D. 9441) contains errors that may prove to be misleading and are in need of clarification. ***** Correction of Publication Accordingly, 26 CFR part 1 is cor- rected by making the following correcting amendments: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.482–0T is amended by revising the entries of §1.482–2T(f)(2) and §1.482–7T(e), (g)(2)(ix)(D)(2), (g)(4)(i)(D), and (h)(3)(vi)(B) as follows: §1.482–0T Outline of regulations under section 482 (temporary). ***** §1.482–2T Determination of taxable income in specific situations (temporary). ***** (f) * * * (2)Electiontoapplyparagraph(b)to earlier taxable years. ***** §1.482–7T Methods to determine taxable income in connection with a cost sharing arrangement (temporary). ***** (e) Reasonably anticipated benefits share. ***** (g) * * * (2) * * * (ix) * * * (D)*** (2) One variable input parameter. ***** (4) * * * (i) * * * (D) Only one controlled participant with nonroutine platform contributions. ***** (h) * * * (3) * * * (vi)*** (B) Circumstances in which Periodic Trigger deemed not to occur. ***** Par. 3. Section 1 .482–7A is amended by revising the a pplicable date as follows: §1.482–7A Sharing of costs. Regulations applicable on or before January 4, 2009. ***** Par. 4. Section 1.482–7T is amended as follows: 1. Paragraph (b)(5)(iii)Example 4.(i) is revised. 2. The fifth sentence of paragraph (b)(5)(iii)Example 4.(iii) is revised. 3. The first two sentences of paragraph (c)(3) are revised. 4. The last sentence of paragraph (g)(4)(i)(E) is revised. 5. The second sentence of paragraph (g)(4)(i)(F)(1) is revised. 6. The first sentence of paragraph (g)(4)(vi) is revised. 7. The first sentence of paragraph (g)(7)(v)Example 1.(i) is revised. 8. The seventh sentence of paragraph (g)(7)(v)Example 1.(ii) is revised. 9. The last sentence of paragraph (g)(7)(v)Example 1.(iii) is revised. 10. The last sentence of paragraph (g)(7)(v)Example 1.(iv) is revised. 11. The last sentence of paragraph (g)(7)(v)Example 2.(iii) is revised. 12. The second, fourth and last sen- tences of paragraph (g)(7)(v)Example 2.(iv) are revised. 13. The first sentence of paragraph (k)(1)(iv)(B)Example 1. is revised. 14. The first sentence of paragraph (k)(1)(iv)(B)Example 2. is revised. 15. Paragraph (k)(1)(iv)(B)Example 2.(i) is revised. 16. The first sentence of paragraph (k)(3)(ii) is revised. 17. Paragraph (k)(4)(i) is revised. 18. Paragraph (m)(2)(viii) is revised. §1.482–7T Methods to determine taxable income in connection with a cost sharing arrangement (temporary). ***** (b) * * * 2009–20 I.R.B.1022May 18, 2009 (5) * * * (iii) * * * Example 4.*** (i) The facts are the same as inExample 1except that P does not own proprietary software and P and S use a method for determining the arm’s length amount of the PCT Payment for the P-Cap patent rights dif- ferent from the method used inExample 1. ***** (iii) * * * See §1.482–4(c)(4). * * * ***** (c) * * * (3) * * * For purposes of §1.482–1(b)(2)(ii) and paragraph (a)(2) of this section, a PCT must be identified by the controlled participants as a particular type of transaction (for example, a license for royalty payments). See paragraph (k)(2)(ii)(H) of this section. * * * ***** (g) * * * (4) * * * (i) * * * (E) * * * For converting to another form of payment, see generally §1.482–7T(h) (Form of payment rules). (F) * * * (1)***See, forexample, §1.482–7T(g)(2)(v)(B)(1) (Discount rate variation between realistic alternatives). *** ***** (vi) * * * For purposes of this para- graph (g)(4), any routine contributions that are platform or operating contributions, the valuation and PCT Payments for which are determined and made independently of the income method, are treated similarly to cost contributions and operating cost con- tributions, respectively. * * * ***** (7) * * * (v) * * * Example 1. *** (i) USP, a U.S. electronic data storage company, has partially developed technology for a type of ex- tremely small compact storage devices (nanodisks) which are expected to provide a significant increase in data storage capacity in various types of portable devices such as cell phones, MP3 players, laptop computers and digital cameras. * * * (ii) * * * FS undertakes routine distribution ac- tivities in its markets that constitute routine contri- butions to the relevant business activity of exploiting nanodisk technologies. * * * (iii) * * * Therefore, the present value of the non- routine residual divisional profit is $1.336 billion. (iv) * * * Therefore, FS’s PCT payments should have an expected present value equal to $802 million (.6 x $1.336 billion). Example 2. *** (iii) * * * Therefore, the present value of the non- routine residual divisional profit in USP’s territory is $39,243X and in CFC’s territory is $19,622X (for simplicity of calculation in this example, all financial flows are assumed to occur at the beginning of each period). (iv) * * * Consequently, the present value of the arm’s length amount of the PCT payments that USP should pay to FS for FS’s platform contribution is $10,007X(.255x$39,243X).***Consequently, the present value of the arm’s length amount of the PCT payments that FS should pay to USP for USP’s platform contribution is $12,362 (.63 x $19,622X). Therefore, FS is required to make a net payment to USP with a present value of $2,355X ($12,362X - $10,007X). ***** (k) * * * (1) * * * (iv) * * * (B)*** Example 1. The contractual provisions recorded upon formation of an arrangement that purports to be a CSA provide that PCT payments with respect to a particular platform contribution will consist of payments contingent on sales. * * * Example 2. An arrangement that purports to be a CSA provides that PCT payments with respect to a particular platform contribution shall be contingent payments equal to 10% of sales of products that in- corporate cost shared intangibles. * * * (i) The contingent payment terms with respect to the platform contribution do not have economic substance because the con- trolled participants did not act in accor- dance with their upfront risk allocation; or ***** (3) * * * (ii) * * * For purposes of this section, the controlled participants may not rely solely upon financial accounting to estab- lish satisfaction of the accounting require- ments of this paragraph (k)(3). * * * (4) * * * (i)***Eachcontrolledparticipant must file with the Internal Revenue Ser- vice, in the manner described in this paragraph (k)(4), a “Statement of Con- trolled Participant to §1.482–7T Cost Sharing Arrangement” (CSA Statement) that complies with the requirements of this paragraph (k)(4). ***** (m) * * * (2) * * * (viii) Paragraph (k)(4)(iii)(A) of this section shall be construed as requiring a CSA Statement with respect to the revised written contractual agreement described in paragraph (m)(2)(vi) of this section no later than September 2, 2009. ***** LaNita Van Dyke, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). (Filed by the Office of the Federal Register on March 4, 2009, 8:45 a.m., and published in the issue of the Federal Register for March 5, 2009, 74 F.R. 9570) The Allocation of Consideration and Allocation and Recovery of Basis in Transactions Involving Corporate Stock or Securities; Correction Announcement 2009–40 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correction to notice of pro- posed rulemaking. SUMMARY: This document contains a correction to a notice of proposed rule- making (REG–143686–07, 2009–8 I.R.B. 579) that was published in theFederal Registeron Wednesday, January 21, 2009 (74 FR 3509) providing guidance regarding the recovery of stock basis in distributions under section 301 and transactions that are treated as dividends to which section 301 applies, as well as guidance regarding the determination of gain and the basis of stock or securities received in exchange for, or with respect to, stock or securities in certain transactions. The proposed regulations affect shareholders and security holders of corporations. These proposed regulations are necessary to provide such shareholders and security holders with guidance regarding the allocation and recovery of basis on distributions of property. FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations under sections 301, 302, and 304, Theresa Kolish, (202) 622–7530; concerning the proposed regulations under sections 351, 354, 355, 356, 358, 368, May 18, 200910232009–20 I.R.B. 1001, and 1016, Rebecca O. Burch, (202) 622–7550; concerning the proposed regu- lations under section 861, Jeffrey L. Parry, (202) 622–4476 (not toll-free numbers). SUPPLEMENTARY INFORMATION Background The correction notice that is the subject of this document is under sections 301, 302, 304, 351, 354, 355, 356, 358, 368, 861, 1001, 1016, and 1374 of the Internal Revenue Code. Need for Correction As published, the notice of proposed rulemaking (REG–143686–07) contains errors that may proveto be misleading and are in need of clarification. Correction of Publication Accordingly, the publication of the notice of proposed rulemaking (REG–143686–07), which was the sub- ject of FR Doc. E9–1100, is corrected as follows: 1. On page 3509, column 2, in the pre- amble, under the caption “SUMMARY:”, line 3, the language “301, 302, 304, 351, 354, 356, 358, 368,” is corrected to read “301, 302, 304, 351, 354, 355, 356, 358, 368,”. 2. On page 3509, column 3, in the pre- amble, under the caption “FOR FURTHER INFORMATION CONTACT:”, line 5, the language “under sections 351, 354, 356, 358, 368,” is corrected to read “under sec- tions 351, 354, 355, 356, 358, 368,”. 3. On page 3510, column 1, in the preamble, under the paragraph heading “Explanation of Provisions”, second para- graph, line 6, the language “lead to the possibility of variant” is corrected to read “led to the possibility of variant”. 4. On page 3510, column 1, in the preamble, under the paragraph head- ing “Explanation of Provisions”, second paragraph, line 5 from the bottom of the paragraph, the language “was needed re- considered. See REG–” is corrected to read “needed reconsideration. See REG–”. 5. On page 3510, column 2, in the preamble, under the paragraph heading “Explanation of Provisions”, second para- graph of the column, line 2, the language “that a share of stock is the basic unit of” is corrected to read “that a share of stock is a basic unit of”. 6. On page 3511, column 2, in the pre- amble, under the paragraph heading “C. Dividend Equivalent Reorganization Ex- changes”, first paragraph of the column, line 7 from the bottom of the paragraph, the language “of stock solely for nonquali- fying” is corrected to read “of stock solely for qualifying”. §1.301–2 [Corrected] 7.On page 3513, column 3, §1.301–2(a)Example.(i), last line of the column, the language “$25 (Block 1) and 75 were acquired on Date” is corrected to read “$25 (block 1) and 75 were acquired on Date”. 8.On page 3514, column 1, §1.301–2(a)Example.(i), first line of the column, the language “2 for $175 (Block 2). On December 31, when” is corrected to read “2 for $175 (block 2). On Decem- ber 31, when”. §1.302–5 [Corrected] 9.On page 3514, column 1, §1.302–5(a)(3)(i), line 4 from the bottom of the column, the language “treated as loss. If all the shares of the” is corrected to read “treated as a loss.Ifalltheshares of the”. 10.On page 3515, column 1, §1.302–5(e)Example 2.(ii), last line, the language “5(a)(3)(ii)).” is corrected to read “5(a)(4)).”. 11.On page 3515, column 1, §1.302–5(e)Example 3.(ii), line 2 from the bottom of the column, the language “shares of common stock. Therefore, the only” is corrected to read “shares of pre- ferred stock. Therefore, the only”. 12.On page 3515, column 2, §1.302–5(e)Example 4.(i), last line, the language “stock of Y.” is corrected to read “stock of Corporation Y.”. 13.On page 3515, column 2, §1.302–5(e)Example 4.(ii), line 4, the language “deferred loss on a disposition of the” is corrected to read “deferred loss on the disposition of the”. §1.304–2 [Corrected] 14.On page 3515, column 3, §1.304–2(a), the language “In general”is corrected to read “In general—”. 15.On page 3515, column 3, §1.304–2(a)(1), lines 1 through 3 from the bottom of the paragraph, the language “302(a) or 303 does not apply. For the amount constituting a dividend in such cases, see §1.304–6.” is corrected to read “302(a) or 303 does not apply.”. 16.On page 3515, column 3, §1.304–2(a)(3), line 2 from the bottom of the paragraph, the language “transferors basis in the stock of the” is corrected to read “transferor’s basis in the stock of the”. 17.On page 3516, column 1, §1.304–2(c), line 2, the language “exam- ples in this section, each of” is corrected to read “examples in this section, each”. 18.On page 3516, column 2, §1.304–2(c)Example 3.(i), line 4, the lan- guage “common) and then acquired all of the” is corrected to read “common stock) and then acquired all of the”. 19.On page 3516, column 3, §1.304–2(c)Example 3.(i), first line of the column, the language “common stock for $100). Only corporation Y” is corrected to read “common stock for $100). Only Corporation Y”. 20.On page 3516, column 3, §1.304–2(c)Example 3.(ii), lines 4 through 11 from the bottom of the para- graph, the language “other 2 blocks of corporation Y shares. After the redemp- tion transaction, all of Corporation W’s shares in corporation Y, including the deemed shares that are redeemed, are treated as exchanged in a recapitalization described in section 368(a)(1)(E). As a result, corporation W will have 100 shares in corporation Y, 50 shares” is corrected to read “other 2 blocks of Corporation Y shares. After the redemption transaction, all of Corporation W’s shares in Corpora- tion Y, including the deemed shares that are redeemed, are treated as exchanged in a recapitalization described in section 368(a)(1)(E). As a result, Corporation W will have 100 shares in Corporation Y, 50 shares”. §1.351–2 [Corrected] 21.On page 3517, column 2, §1.351–2(b)Example., line 11, the lan- guage “to C. Gain, but not loss, is recog- nized by D.” is corrected to read “by C. Gain, but not loss, is recognized by D.”. 2009–20 I.R.B.1024May 18, 2009 22. On page 3517, column 2, §1.351–2(b)Example., line 9 from the bottom of the paragraph, the language “of $100 (B) $30 cash and 30 shares of stock” is corrected to read “of $100); (B) $30 cash and 30 shares of stock”. §1.355–1 [Corrected] 23. On page 3518, column 2, §1.355–1(e)(2), line 13, the language “sec- tion 356 or both sections 355 and 356” is corrected to read “section 356, or both sections 355 and 356”. §1.356–1 [Corrected] 24. On page 3518, column 3, §1.356–1(d)Example 3.(i), lines 3 through 7, the language “on Date 1 for $3 each (Block 1) and 10 shares of stock of Cor- poration X on Date 2 for $9 each (Block 2). On Date 3, Corporation Y acquires the assets of Corporation Xin a reorganization under section 368(a)(1)(A).” is corrected to read “on Date 1 for $3 each (block 1) and 10 shares of stock of Corporation X on Date 2 for $9 each (block 2). On Date 3, Corporation Y acquires the assets of Cor- poration X in a reorganization described in section 368(a)(1)(A).”. 25. On page 3518, column 3, §1.356–1(d)Example 3.(ii), lines 14 through 18, the language “exchange of the Block 1 shares of Corporation X stock, $50 of which is recognized under section 356 and paragraph (a) of this section, and J realizes a gain of $10 on the exchange of the Block 2 shares of Corporation X stock,” is corrected to read “exchange of the block 1 shares of Corporation X stock, $50 of which is recognized under section 356 and paragraph (a) of this section, and J realizes a gain of $10 on the exchange of the block 2 shares of Corporation X stock,”. 26. On page 3518, column 3, §1.356–1(d)Example 4.(i), lines 5 through 7, the language “exchange for J’s Block 1 shares of stock of Corporation X and $100 of cash in exchange for J’s Block 2 shares of stock of corporation X.” is corrected to read “exchange for J’s block 1 shares of stock of Corporation X and $100 of cash in exchange for J’s block 2 shares of stock of Corporation X.”. 27. On page 3518, column 3, §1.356–1(d)Example 4.(ii), lines 4 through 12, the language “Corporation Y in exchange for J’s Block 1 shares of stock of Corporation X and $100 of cash in exchange for J’s Block 2 shares of stock of Corporation X and such terms are eco- nomically reasonable, such terms control. J realizes a gain of $70 on the exchange of the Block 1 shares of stock, none of which is recognized under section 354. J real- izes a gain of $10 on the exchange of the Block 2” is corrected to read “Corporation Y in exchange for J’s block 1 shares of stock of Corporation X and $100 of cash in exchange for J’s block 2 shares of stock of Corporation X and such terms are eco- nomically reasonable, such terms control. J realizes a gain of $70 on the exchange of the block 1 shares of stock, none of which is recognized under section 354. J realizes a gain of $10 on the exchange of the block 2”. §1.358–1 [Corrected] 28.On page 3519, column 2, §1.358–1(d)Example., line 11, the lan- guage “the distribution of a dividend. A’s ratable” is corrected to read “a distribution of a dividend. A’s ratable”. §1.358–2 [Corrected] 29.On page 3519, column 3, §1.358–2(a)(1), line 4, the language “dis- tribution to which section 354, 355” is corrected to read “distribution to which section 354, 355,”. 30.On page 3519, column 3, §1.358–2(b), line 6, the language “section 354, 355 or 356, the following” is cor- rected to read “section 354, 355, or 356, the following”. 31.On page 3521, column 3, §1.358–2(g)(2), line 4, the language “sec- tion 351 applies stock or stock and” is corrected to read “section 351 applies, stock or stock and”. 32.On page 3522, column 1, §1.358–2(i)Example 1.(i), line 6, the language “of Corporation X in a reorga- nization under” is corrected to read “of Corporation X in a reorganization de- scribed in”. 33.On page 3522, column 1, §1.358–2(i)Example 1.(ii), line 2 from the bottom of the paragraph, the language “of corporation Y stock have a basis of $1.50” is corrected to read “of Corporation Y stock have a basis of $1.50”. 34.On page 3522, column 1, §1.358–2(i)Example 2.(i), line 5 from the bottom of the column, the language “shares of corporation Y stock. Again, J is not” is corrected to read “shares of Corporation Y stock. Again, J is not”. 35.On page 3522, column 2, §1.358–2(i)Example 3.(i), line 10, the language “a reorganization under sec- tion 368(a)(1)(E).”is corrected to read “a reorganization described in section 368(a)(1)(E).”. 36.On page 3522, column 3, §1.358–2(i)Example 5.(ii), line 10, the language “is not dividend equivalent, such terms” is corrected to read “does not have the effect of a dividend, such terms”. 37.On page 3523, column 1, §1.358–2(i)Example 6.(i), line 8, the language “reorganization under sec- tion 368(a)(1)(A).” is corrected to read “reorganization described in section 368(a)(1)(A).”. 38.On page 3523, column 1, §1.358–2(i)Example 7.(i), line 6, the language “of Corporation X in a reorga- nization under” is corrected to read “of Corporation X in a reorganization de- scribed in”. 39.On page 3523, column 2, §1.358–2(i)Example 8.(ii), line 5, the lan- guage “liability of J, the rules of paragraph (g) this” is corrected to read “liability of J, the rules of paragraph (g) of this”. 40.On page 3523, column 2, §1.358–2(i)Example 9.(i), lines 9 through 11, the language “Corporation X in a re- organization under section 368(a)(1)(D). Pursuant to the terms of the plan of reor- ganization, J surrenders J’s” is corrected to read “Corporation X in a reorganiza- tion described in section 368(a)(1)(D). Pursuant to the terms of the plan of reor- ganization, J surrenders”. 41.On page 3523, column 2, §1.358–2(i)Example 9.(ii), line 5 from the bottom of the column, the language “recapitalized in a reorganization under” is corrected to read “recapitalized in a reorganization described in”. 42.On page 3523, column 3, §1.358–2(i)Example 10.(i), lines 12 thru 14, the language “Corporation X in a re- organization under section 368(a)(1)(D). Pursuant to the terms of the plan of reor- ganization, J surrenders J’s” is corrected to read “Corporation X in a reorganiza- tion described in section 368(a)(1)(D). May 18, 200910252009–20 I.R.B. Pursuant to the terms of the plan of reor- ganization, J surrenders”. 43. On page 3523, column 3, §1.358–2(i)Example 10.(ii), line 10 from the bottom of the column, the language “be recapitalized in a reorganization un- der” is corrected to read “be recapitalized in a reorganization described in”. 44. On page 3524, column 2, §1.358–2(i)Example 13.(i), line 9, the language “reorganization under sec- tion 368(a)(1)(A).” is corrected to read “reorganization described in section 368(a)(1)(A).”. 45. On page 3524, column 3, §1.358–2(i)Example 14.(i), line 9, the language “reorganization under sec- tion 368(a)(1)(A),” is corrected to read “reorganization described in section 368(a)(1)(A),”. 46. On page 3525, column 1, §1.358–2(i)Example 15.(ii), line 3 from the bottom of the paragraph, the language “each has a basis of $6 and is treated as having” is corrected to read “each has a basis of $5 and is treated as having”. 47. On page 3525, column 1, §1.358–2(i)Example 16.(i), line 4, the language “Shares ofCorporation Y in an exchange to” is corrected to read “Shares ofCorporationYstockinanexchangeto”. 48. On page 3525, column 1, §1.358–2(i)Example 17.(i), line 2, the language “Facts.The facts are the same as Example 1,” is corrected to read “Facts. The facts are the same as Example 16,”. §1.358–6 [Corrected] 49. On page 3525, column 2, §1.358–6(f)(3), line 4 from the bottom of the paragraph, the language “1 revised April 1, 2008 for the year” is corrected to read “1 revised April 1 for the year”. §1.861–12 [Corrected] 50. On page 3525, column 3, §1.861–12(c)(2)(vi), lines 1 through 3, the language “Adjustments in respect of redeemed stock for taxpayers using the tax book value method. Solely for” is corrected to read “Adjustments in respect of redeemed stock for taxpayers using the tax book value method. Solely for”. 51. On page 3525, column 3, §1.861–12(c)(2)(vi), lines 13 through 15, the language “taken into account un- der §1.302–5(a)(3) as of the close of the redeemed shareholder’s taxable year (un- recovered” is corrected to read “taken into account under §1.302–5 as of the close of the redeemed shareholder’s taxable year (deferred”. 52.On page 3525, column 3, §1.861–12(c)(2)(vi), line 4 from the bot- tom of the column, the language “unre- covered loss (and allocated among” is corrected to read “deferred loss (and allo- cated among”. §1.1001–6 [Corrected] 53.On page 3526, column 2, §1.1001–6(c), line 10 from the top of the column, the language “still unliquidated. Solely for purposes of” is corrected to read “still unliquidated investment. Solely for purposes of”. LaNita Van Dyke, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). (Filed by the Office of the Federal Register on March 4, 2008, 8:45 a.m., and published in the issue of the Federal Register for March 5, 2009, 74 F.R. 9575) Deletions From Cumulative List of Organizations Contributions to Which are Deductible Under Section 170 of the Code Announcement 2009–41 The Internal Revenue Service has re- voked its determination that the organi- zations listed below qualify as organiza- tions described in sections 501(c)(3) and 170(c)(2) of the Internal Revenue Code of 1986. Generally, the Service will not disallow deductions for contributions made to a listed organization on or before the date of announcement in the Internal Revenue Bulletin that an organization no longer qualifies. However, the Service is not precluded from disallowing a deduction for any contributions made after an or- ganization ceases to qualify under section 170(c)(2) if the organization has not timely filed a suit for declaratory judgment under section 7428 and if the contributor (1) had knowledge of the revocation of the ruling or determination letter, (2) was aware that such revocation was imminent, or (3) was in part responsible for or was aware of the activities or omissions of the organization that brought about this revocation. If on the other hand a suit for declara- tory judgment has been timely filed, con- tributions from individuals and organiza- tions described in section 170(c)(2) that are otherwise allowable will continue to be deductible. Protection under section 7428(c) would begin on May 18, 2009, and would end on the date the court first deter- mines that the organization is not described in section 170(c)(2) as more particularly set forth in section 7428(c)(1). For indi- vidual contributors, the maximum deduc- tion protected is $1,000, with a husband and wife treated as one contributor. This benefit is not extended to any individual, in wholeorinpart,fortheactsoromissions of the organization that were the basis for revocation. Michael and Laura Gallop Family Foundation Agoura Hills, CA Physician Directed Care Southfield, MI Winston County Community Development Corporation Louisville, MS EMF Debt Management Inc. Pittsburgh, PA Lil Pals & Gals Daycare Center Association Tulsa, OK Heartland Women’s Foundation, Inc. Tribune, KS CF Moore Charitable Foundation Chicago, IL Waimano Auxiliary a/k/a Kokua Mau Work Center Ewa Beach, HI The American Dream West Jordan, UT Henry Jacobson Family Foundation Ross, CA Dreamkeepers of America Inc. Memphis, TN Community Workshop on Economic Development Pueblo, CO Hope Alive, Inc. Pueblo, CO Building Successful Lifestyles, Inc. Topeka, KS 2009–20 I.R.B.1026May 18, 2009 Hummingbird Tribal Foundation Woodside, CA Diamond-A-CAT-A-ME, Inc. Houston, TX Constitutional Educational Research Foundation Rancho Cordova, CA Family Home Providers, Inc. Cumming, GA Special Rules To Reduce Section 1446 Withholding; Correction Announcement 2009–42 AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Correcting amendments. SUMMARY: This document contains cor- rections to final regulations (T.D. 9394, 2008–21 I.R.B. 988) that were published in theFederal Registeron Tuesday, April 29, 2008 (73 FR 23069) regarding when a partnership may consider certain deduc- tions and losses of a foreign partner to re- duce or eliminate the partnership’s obliga- tion to pay withholding tax under section 1446 on effectively connected taxable in- come allocable under section 704 to such partner. The regulations will affect part- nerships engaged in a trade or business in the United States that have one or more for- eign partners. DATES: This correction is effective on April 2, 2009, and is applicable on April 29, 2008. FOR FURTHER INFORMATION CONTACT: Ronald M. Gootzeit at (202) 622–3860 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background The final regulationsthat are the subject of this document are under sections 1446, 1464, 6071, 6091, 6151, 6302, and 6414 of the Internal Revenue Code. Need for Correction As published, final regulations (T.D. 9394) contains errors that may prove to be misleading and are in need of clarification. ***** Correction of Publication Accordingly, 26 CFR part 1 is cor- rected by making the following correcting amendments: PART 1—INCOME TAXES Paragraph 1. The authority citation for part 1 continues to read in part as follows: Authority: 26 U.S.C. 7805 * * * Par. 2. Section 1.1446–6 is amended as follows: 1. Paragraph (c)(2)(i) is revised. 2. The last sentence of paragraph (d)(3)(ii) is revised and a new sentence is added at the end of the paragraph. 3. Paragraphs (e)(1)(vi) second oc- currence, (e)(1)(vii), and (e)(1)(viii) are redesignated as paragraphs (e)(1)(vii), (e)(1)(viii), and (e)(1)(ix), respectively. 4. The first sentence of paragraph (e)(2) Example 2.(i) is revised. 5. The third and fourth sentences of paragraph (e)(2)Example 2.(ii) are re- vised. 6. The fourth sentence of paragraph (e)(2)Example 4. is revised. 7. Paragraph (e)(2)Example 6.(ii) is revised. The revisions and addition read as fol- lows: §1.1446–6 Special rules to reduce a partnership’s 1446 tax with respect to a foreign partner’s allocable share of effectively connected taxable income. ***** (c) * * * (2) * * * (i)Form of certification. A partner’s certification to a partnership under para- graph (c)(1)(i) or (iii) of this section shall be made using Form 8804–C, “Certificate Of Partner-Level Items to Reduce Section 1446 Withholding,”in accordance with the instructions of the form and the rules of this section. ***** (d) * * * (3) * * * (ii)***Topermitthepartnershipto reasonably rely on such certificate, the partnership shall be considered to have satisfied the requirements of paragraph (d)(3)(i) of this section if the partnership demonstrates that such failure was due to reasonable cause and not willful ne- glect and if once the partnership becomes aware of the failure, the partnership at- taches the certificate and computation, as well as a written statement setting forth the reasons for the failure to comply with the requirements of paragraph (d)(3)(i) of this section, to an amended Form 8813 or amended Forms 8804 and 8805 for the relevant period. All such submissions should be sent to the address provided in the instructions to Form 8804–C. ***** (e) * * * (2) * * * Example 2. *** (i) Assume the same facts as in Example 1. * * * (ii) * * * As described in Example 1, NRA’s year 4 U.S. income tax return is a qualifying U.S. income tax return because it will report income or gain effec- tively connected with a U.S. trade or business and is described under paragraph (b)(2)(iii)(C) of this sec- tion. Although NRA’s year 5 U.S. income tax return reportsincomeorgaineffectivelyconnectedwitha U.S. trade or business or deductions or losses prop- erly allocated and apportioned to such activities it is not a qualifying U.S. income tax return under para- graph (b)(2)(iii) of this section. * * * ***** Example 4. ***NRAtimely-filed(withinthe meaning of paragraph (b)(2) of this section) U.S. in- come tax returns for years 1 through 6 reporting its al- locable share of ECTI (or loss) from XYZ (and timely paid all tax shown on such returns). * * * ***** Example 6. *** (ii) If PRS had considered only $900 (or a lesser amount) of NRA’s certified net operating loss when computing and paying its 1446 tax during year 4 then, under paragraph (d)(2)(iii) of this section, PRS would not be liable for 1446 tax because it did not consider a net operating loss greater than the amount actually available to NRA. Par. 3. Section 1.1464–1 is amended by revising paragraph (c) to read as follows: §1.1464–1 Refunds or credits. ***** (c)Effective/Applicability date.The last sentence in paragraph (a) of this sec- tion shall apply to partnership taxable years beginning afterApril 29, 2008. Par. 4. Section 1.6151–1 is amended by revising paragraph (e) to read as follows: §1.6151–1 Time and place for paying tax shown on returns. ***** May 18, 200910272009–20 I.R.B. (e)Effective/Applicability date. Para- graph (d)(2) of this section shall apply to publicly traded partnerships described in §1.1446–4 for partnership taxable years beginning afterApril 29, 2008. ***** LaNita Van Dyke, Chief, Publications and Regulations Branch, Legal Processing Division, Associate Chief Counsel (Procedure and Administration). (Filed by the Office of the Federal Register on April 1, 2009, 8:45 a.m., and published in the issue of the Federal Register for April 2, 2009, 74 F.R. 14931) 2009–20 I.R.B.1028May 18, 2009 Definition of Terms Revenue rulings and revenue procedures (hereinafter referred to as “rulings”) that have an effect on previous rulings use the following defined terms to describe the ef- fect: Amplifieddescribes a situation where no change is being made in a prior pub- lished position, but the prior position is be- ingextendedtoapplytoavariationofthe fact situation set forth therein. Thus, if an earlier ruling held that a principle ap- plied to A, and the new ruling holds that the same principle also applies to B, the earlier ruling is amplified. (Compare withmodi- fied,below). Clarifiedis used in those instances where the language in a prior ruling is be- ing made clear because the language has caused, or may cause, some confusion. It is not used where a position in a prior ruling is being changed. Distinguisheddescribes a situation where a ruling mentions a previously pub- lished ruling and points out an essential difference between them. Modifiedis used where the substance of a previously published position is being changed. Thus, if a prior ruling held that a principle applied to A but not to B, and the new ruling holds that it applies to both A and B, the prior ruling is modified because it corrects a published position. (Compare withamplifiedandclarified, above). Obsoleteddescribes a previously pub- lished ruling that is not considered deter- minative with respect to future transac- tions. This term is most commonly used in a ruling that lists previously published rul- ings that are obsoleted because of changes in laws or regulations. A ruling may also be obsoleted because the substance has been included in regulations subsequently adopted. Revokeddescribes situations where the position in the previously published ruling is not correct and the correct position is beingstatedinanewruling. Supersededdescribes a situation where the new ruling does nothing more than re- state the substance and situation of a previ- ously published ruling (or rulings). Thus, the term is used to republish under the 1986 Code and regulations the same po- sition published under the 1939 Code and regulations. The term is also used when it is desired to republish in a single rul- ing a series of situations, names, etc., that were previously published over a period of time in separate rulings. If the new rul- ing does more than restate the substance of a prior ruling, a combination of terms is used. For example,modifiedandsu- persededdescribes a situation where the substance of a previously published ruling is being changed in part and is continued without change in part and it is desired to restate the valid portion of the previously published ruling in a new ruling that is self contained. In this case, the previously pub- lished ruling is first modified and then, as modified, is superseded. Supplementedis used in situations in which a list, such as a list of the names of countries, is published in a ruling and that list is expanded by adding further names in subsequent rulings. After the original rul- ing has been supplemented several times, a new ruling may be published that includes the list in the original ruling and the ad- ditions, and supersedes all prior rulings in the series. Suspendedis used in rare situations to show that the previous published rulings will not be applied pending some future action such as the issuance of new or amended regulations, the outcome of cases in litigation, or the outcome of a Service study. Abbreviations The fol lowing abbreviations in current use and for merly used will appear in material publis hedintheBulletin. A—Individual. Acq.—A cquiescence. B—Individual. BE—Beneficiary. BK—Bank . B.T.A.—Board of Tax Appeals. C—Individual. C.B.—Cu mulative Bulletin. CFR—Code of Federal Regulations. CI—City. COOP—Coo perative. Ct.D.—Court Decision. CY—County. D—Decede nt. DC—Dummy Corporation. DE—Donee. Del. Order —Delegation Order. DISC—Domestic International Sales Corporation. DR—Donor. E—Estate. EE—Employee. E.O.—Executive Order. ER—Emp loyer. ERISA—Employee Retirement Income Security Act. EX—Executor. F—Fiduc iary. FC—Foreign Country. FICA—Federal Insurance Contributions Act. FISC—Fo reign International Sales Company. FPH—Foreign Personal Holding Company. F.R.—Federal Register. FUTA—Fed eral Unemployment Tax Act. FX—Foreign corporation. G.C.M.—Chief Counsel’s Memorandum. GE—Grante e. GP—General Partner. GR—Grantor. IC—Insura nce Company. I.R.B.—Internal Revenue Bulletin. LE—Lessee. LP—Limited Partner. LR—Lessor. M—Minor. Nonacq.—No nacquiescence. O—Organization. P—Parent Corporation. PHC—Persona l Holding Company. PO—Possession of the U.S. PR—Partner. PRS—Pa rtnership. PTE—Prohibited Transaction Exemption. Pub. L.—Public Law. REIT—Re al Estate Investment Trust. Rev. Proc.—Revenue Procedure. Rev. Rul.—Revenue Ruling. S—Subsi diary. S.P.R.—Statement of Procedural Rules. Stat.—Statutes at Large. T—Target Corporation. T.C.—Tax Court. T.D.—Treasury Decision. TFE—Trans feree. TFR—Transferor. T.I.R.—Technical Information Release. TP—Taxpay er. TR—Trust. TT—Trustee. U.S.C.—Uni ted States Code. X—Corporation. Y—Corporation. Z—Corporat ion. May 18, 2009i2009–20 I.R.B. Numerical Finding List 1 Bulletins 2009–1 through 2009–20 Announcements: 2009-1, 2009-1 I.R.B.242 2009-2, 2009-5 I.R.B.424 2009-3, 2009-6 I.R.B.459 2009-4, 2009-8 I.R.B.597 2009-5, 2009-8 I.R.B.569 2009-6, 2009-9 I.R.B.643 2009-7, 2009-10 I.R.B.663 2009-8, 2009-8 I.R.B.598 2009-9, 2009-9 I.R.B.643 2009-10, 2009-9 I.R.B.644 2009-11, 2009-10 I.R.B.663 2009-12, 2009-11 I.R.B.686 2009-13, 2009-11 I.R.B.686 2009-14, 2009-11 I.R.B.687 2009-15, 2009-11 I.R.B.687 2009-16, 2009-11 I.R.B.691 2009-17, 2009-12 I.R.B.714 2009-18, 2009-12 I.R.B.714 2009-19, 2009-12 I.R.B.715 2009-20, 2009-12 I.R.B.716 2009-21, 2009-13 I.R.B.730 2009-22, 2009-13 I.R.B.731 2009-23, 2009-13 I.R.B.731 2009-24, 2009-13 I.R.B.732 2009-25, 2009-14 I.R.B.755 2009-26, 2009-14 I.R.B.755 2009-27, 2009-14 I.R.B.756 2009-28, 2009-15 I.R.B.760 2009-29, 2009-14 I.R.B.757 2009-30, 2009-15 I.R.B.794 2009-31, 2009-15 I.R.B.798 2009-32, 2009-15 I.R.B.799 2009-33, 2009-15 I.R.B.799 2009-34, 2009-18 I.R.B.916 2009-35, 2009-17 I.R.B.892 2009-36, 2009-18 I.R.B.927 2009-37, 2009-19 I.R.B.940 2009-38, 2009-19 I.R.B.940 2009-39, 2009-20 I.R.B.1022 2009-40, 2009-20 I.R.B.1023 2009-41, 2009-20 I.R.B.1026 2009-42, 2009-20 I.R.B.1027 Notices: 2009-1, 2009-2 I.R.B.250 2009-2, 2009-4 I.R.B.344 2009-3, 2009-2 I.R.B.250 2009-4, 2009-2 I.R.B.251 2009-5, 2009-3 I.R.B.309 2009-6, 2009-3 I.R.B.311 2009-7, 2009-3 I.R.B.312 Notices— Continued: 2009-8, 2009-4 I.R.B.347 2009-9, 2009-5 I.R.B.419 2009-10, 2009-5 I.R.B.419 2009-11, 2009-5 I.R.B.420 2009-12, 2009-6 I.R.B.446 2009-13, 2009-6 I.R.B.447 2009-14, 2009-7 I.R.B.516 2009-15, 2009-6 I.R.B.449 2009-16, 2009-8 I.R.B.572 2009-17, 2009-8 I.R.B.575 2009-18, 2009-10 I.R.B.648 2009-19, 2009-10 I.R.B.660 2009-20, 2009-12 I.R.B.711 2009-21, 2009-13 I.R.B.724 2009-22, 2009-14 I.R.B.741 2009-23, 2009-16 I.R.B.802 2009-24, 2009-16 I.R.B.817 2009-25, 2009-15 I.R.B.758 2009-26, 2009-16 I.R.B.833 2009-27, 2009-16 I.R.B.838 2009-29, 2009-16 I.R.B.849 2009-30, 2009-16 I.R.B.852 2009-31, 2009-16 I.R.B.856 2009-32, 2009-17 I.R.B.865 2009-33, 2009-17 I.R.B.865 2009-34, 2009-17 I.R.B.876 2009-35, 2009-17 I.R.B.876 2009-36, 2009-17 I.R.B.883 2009-37, 2009-18 I.R.B.898 2009-38, 2009-18 I.R.B.901 2009-39, 2009-18 I.R.B.902 2009-40, 2009-19 I.R.B.931 2009-41, 2009-19 I.R.B.933 2009-42, 2009-20 I.R.B.1011 Proposed Regulations: REG-144615-02, 2009-7 I.R.B.561 REG-144689-04, 2009-18 I.R.B.906 REG-148568-04, 2009-5 I.R.B.421 REG-160872-04, 2009-4 I.R.B.358 REG-158747-06, 2009-4 I.R.B.362 REG-116699-07, 2009-13 I.R.B.727 REG-138326-07, 2009-9 I.R.B.638 REG-143686-07, 2009-8 I.R.B.579 REG-150670-07, 2009-4 I.R.B.378 REG-113462-08, 2009-4 I.R.B.379 REG-147636-08, 2009-9 I.R.B.641 REG-150066-08, 2009-5 I.R.B.423 REG-107845-08, 2009-20 I.R.B.1014 REG-119532-08, 2009-20 I.R.B.1017 Revenue Procedures: 2009-1, 2009-1 I.R.B.1 2009-2, 2009-1 I.R.B.87 2009-3, 2009-1 I.R.B.107 Revenue Procedures— Continued: 2009-4, 2009-1 I.R.B.118 2009-5, 2009-1 I.R.B.161 2009-6, 2009-1 I.R.B.189 2009-7, 2009-1 I.R.B.226 2009-8, 2009-1 I.R.B.229 2009-9, 2009-2 I.R.B.256 2009-10, 2009-2 I.R.B.267 2009-11, 2009-3 I.R.B.313 2009-12, 2009-3 I.R.B.321 2009-13, 2009-3 I.R.B.323 2009-14, 2009-3 I.R.B.324 2009-15, 2009-4 I.R.B.356 2009-16, 2009-6 I.R.B.449 2009-17, 2009-7 I.R.B.517 2009-18, 2009-11 I.R.B.670 2009-19, 2009-14 I.R.B.747 2009-20, 2009-14 I.R.B.749 2009-21, 2009-16 I.R.B.860 2009-22, 2009-16 I.R.B.862 2009-23, 2009-17 I.R.B.884 2009-24, 2009-17 I.R.B.885 2009-26, 2009-19 I.R.B.935 2009-27, 2009-19 I.R.B.938 2009-28, 2009-20 I.R.B.1011 Revenue Rulings: 2009-1, 2009-2 I.R.B.248 2009-2, 2009-2 I.R.B.245 2009-3, 2009-5 I.R.B.382 2009-4, 2009-5 I.R.B.408 2009-5, 2009-6 I.R.B.432 2009-6, 2009-12 I.R.B.694 2009-7, 2009-13 I.R.B.717 2009-8, 2009-10 I.R.B.645 2009-9, 2009-14 I.R.B.735 2009-10, 2009-14 I.R.B.738 2009-11, 2009-18 I.R.B.896 2009-12, 2009-19 I.R.B.928 Tax Conventions: 2009-5, 2009-8 I.R.B.569 Treasury Decisions: 9434, 2009-4 I.R.B.339 9435, 2009-4 I.R.B.333 9436, 2009-3 I.R.B.268 9437, 2009-4 I.R.B.341 9438, 2009-5 I.R.B.387 9439, 2009-5 I.R.B.416 9440, 2009-5 I.R.B.409 9441, 2009-7 I.R.B.460 9442, 2009-6 I.R.B.434 9443, 2009-8 I.R.B.564 9444, 2009-9 I.R.B.603 9445, 2009-9 I.R.B.635 1 A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2008–27 through 2008–52 is in Internal Revenue Bulletin 2008–52, dated December 29, 2008. 2009–20 I.R.B.iiMay 18, 2009 Treasury Decisions— Continued: 9446, 2009-9 I.R.B.607 9447, 2009-12 I.R.B.694 9448, 2009-20 I.R.B.942 May 18, 2009iii2009–20 I.R.B. Finding List of Current Actions on Previously Published Items 1 Bulletins 2009–1 through 2009–20 Notices: 99-35 Obsoleted by Notice 2009-15, 2009-6 I.R.B.449 2001-55 Modified by Notice 2009-1, 2009-2 I.R.B.250 2002-27 Modified by Notice 2009-9, 2009-5 I.R.B.419 2005-74 Obsoleted by T.D. 9446, 2009-9 I.R.B.607 2007-26 Modified by Notice 2009-15, 2009-6 I.R.B.449 2007-52 Clarified, modified, and amplified by Notice 2009-24, 2009-16 I.R.B.817 2007-53 Clarified, modified, and ampilfied by Notice 2009-23, 2009-16 I.R.B.802 2007-54 Obsoleted by T.D. 9436, 2009-3 I.R.B.268 2008-11 Obsoleted by T.D. 9436, 2009-3 I.R.B.268 2008-12 Obsoleted by T.D. 9436, 2009-3 I.R.B.268 Rev. Proc. 2009-11, 2009-3 I.R.B.313 2008-13 Obsoleted by T.D. 9436, 2009-3 I.R.B.268 List of forms modified and superseded by Rev. Proc. 2009-11, 2009-3 I.R.B.313 Modified and clarified by Notice 2009-5, 2009-3 I.R.B.309 2008-46 Obsoleted by T.D. 9436, 2009-3 I.R.B.268 Rev. Proc. 2009-11, 2009-3 I.R.B.313 2008-100 Amplified and superseded by Notice 2009-14, 2009-7 I.R.B.516 Notices— Continued: 2008-110 Modified by Notice 2009-34, 2009-17 I.R.B.876 2009-31 Modified by Notice 2009-42, 2009-20 I.R.B.1011 Proposed Regulations: REG-144615-02 Corrected by Ann. 2009-19, 2009-12 I.R.B.715 REG-149519-03 Withdrawn by Ann. 2009-4, 2009-8 I.R.B.597 REG-148326-05 Corrected by Ann. 2009-14, 2009-11 I.R.B.687 REG-158747-06 Hearing scheduled by Ann. 2009-29, 2009-14 I.R.B.757 REG-143686-07 Corrected by Ann. 2009-40, 2009-20 I.R.B.1023 REG-150066-08 Corrected by Ann. 2009-31, 2009-15 I.R.B.798 Hearing cancelled by Ann. 2009-36, 2009-18 I.R.B.927 Revenue Procedures: 2007-17 Superseded by Rev. Proc. 2009-14, 2009-3 I.R.B.324 2007-66 Modified and superseded by Rev. Proc. 2009-21, 2009-16 I.R.B.860 2007-68 Superseded by Rev. Proc. 2009-17, 2009-7 I.R.B.517 2007-71 Modified by Notice 2009-3, 2009-2 I.R.B.250 2008-1 Superseded by Rev. Proc. 2009-1, 2009-1 I.R.B.1 2008-2 Superseded by Rev. Proc. 2009-2, 2009-1 I.R.B.87 2008-3 Superseded by Rev. Proc. 2009-3, 2009-1 I.R.B.107 Revenue Procedures— Continued: 2008-4 Superseded by Rev. Proc. 2009-4, 2009-1 I.R.B.118 2008-5 Superseded by Rev. Proc. 2009-5, 2009-1 I.R.B.161 2008-6 Superseded by Rev. Proc. 2009-6, 2009-1 I.R.B.189 2008-7 Superseded by Rev. Proc. 2009-7, 2009-1 I.R.B.226 2008-8 Superseded by Rev. Proc. 2009-8, 2009-1 I.R.B.229 2008-9 Superseded by Rev. Proc. 2009-9, 2009-2 I.R.B.256 2008-17 Obsoleted in part by Rev. Proc. 2009-18, 2009-11 I.R.B.670 2008-19 Obsoleted in part by Rev. Proc. 2009-27, 2009-19 I.R.B.938 2008-61 Superseded by Rev. Proc. 2009-3, 2009-1 I.R.B.107 2008-65 Amplified and supplemented by Rev. Proc. 2009-16, 2009-6 I.R.B.449 2008-66 Modified and superseded by Rev. Proc. 2009-21, 2009-16 I.R.B.860 2008-68 Amplified and superseded by Rev. Proc. 2009-15, 2009-4 I.R.B.356 2009-19 Modified and superseded by Rev. Proc. 2009-26, 2009-19 I.R.B.935 Revenue Rulings: 65-286 Obsoleted by T.D. 9435, 2009-4 I.R.B.333 71-381 Obsoleted in part by Rev. Rul. 2009-9, 2009-14 I.R.B.735 76-54 Obsoleted by T.D. 9435, 2009-4 I.R.B.333 1 A cumulative list of current actions on previously published items in Internal Revenue Bulletins 2008–27 through 2008–52 is in Internal Revenue Bulletin 2008–52, dated December 29, 2008. 2009–20 I.R.B.ivMay 18, 2009 Revenue Rulings— Continued: 92-19 Supplemented by Rev. Rul. 2009-3, 2009-5 I.R.B.382 2008-19 Modified by Rev. Rul. 2009-3, 2009-5 I.R.B.382 Treasury Decisions: 9394 Corrected by Ann. 2009-42, 2009-20 I.R.B.1027 9436 Corrected by Ann. 2009-15, 2009-11 I.R.B.687 9438 Corrected by Ann. 2009-30, 2009-15 I.R.B.794 9439 Corrected by Ann. 2009-12, 2009-11 I.R.B.686 9441 Corrected by Ann. 2009-18, 2009-12 I.R.B.714 Ann. 2009-39, 2009-20 I.R.B.1022 9442 Corrected by Ann. 2009-13, 2009-11 I.R.B.686 Ann. 2009-20, 2009-12 I.R.B.716 9446 Corrected by Ann. 2009-23, 2009-13 I.R.B.731 May 18, 2009v2009–20 I.R.B. 2009–20 I.R.B.May 18, 2009 May 18, 20092009–20 I.R.B. INTERNAL REVENUE BULLETIN The Introduction at the beginning of this issue describes the purpose and content of this publication. The weekly Internal Revenue Bulletin is sold on a yearly subscription basis by the Superintendent of Documents. Current subscribers are notified by the Superin- tendent of Documents when their subscriptions must be renewed. 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