T.D. 9448 by ProQuest


More Info
									Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 7520.—Valuation                                      DATES: Effective Date: These regulations         ble S (Single Life Remainder Factors)
Tables                                                       are effective on May 1, 2009.                    and Table U(1) (Unitrust Single Life Re-
                                                                Applicability Date: These regulations         mainder Factors), effective for transfers
26 CFR 1.7520–1: Valuation of annuities unitrust in-
terests, interests for life or terms of years, and remain-
                                                             apply on May 1, 2009.                            for which the valuation date is on or after
der or reversionary interests prior to May 1, 2009.                                                           May 1, 2009, based on data compiled from
                                                             FOR    FURTHER           INFORMATION             the 2000 census as set forth in Life Table
T.D. 9448                                                    CONTACT: Mayer R. Samuels, (202)                 2000CM, and make conforming amend-
                                                             622–3090 (not a toll-free number).               ments to various sections to reflect the
DEPARTMENT OF THE                                                                                             revised tables. At the same time, in the
                                                             SUPPLEMENTARY INFORMATION:
TREASURY                                                                                                      portions of these regulations that are final
                                                                                                              regulations, REG–105643–09, the current
Internal Revenue Service                                     Background
                                                                                                              tables, effective for transfers for which the
26 CFR Parts 1, 20, and 25                                      This document contains amendments             valuation date is after April 30, 1999, and
                                                             to the regulations revising certain tables       before May 1, 2009, are moved to sections
Use of Actuarial Tables in                                                                                    containing actuarial material for historical
                                                             used for the valuation of partial interests
Valuing Annuities, Interests                                 in property under section 7520 of the In-        reference. Table B, Table D, Tables F(4.2)
for Life or Terms of Years, and                              ternal Revenue Code of 1986 (Code) to            through F(14.0), Table J, and Table K,
Remainder or Reversionary                                    reflect the most recent mortality experi-        which are not based on mortality experi-
Interests                                                    ence available.                                  ence, are not changed. Internal Revenue
                                                                                                              Service Publications 1457 “Actuarial Val-
AGENCY: Internal Revenue Service                             In General                                       uations Version 3A” (forthcoming 2009),
(IRS), Treasury.                                                                                              1458 “Actuarial Valuations Version 3B”
                                                                 Section 7520, effective for transfers for    (forthcoming 2009), and 1459 “Actuar-
ACTION: Final and temporary regula-                          which the valuation date is after April 30,      ial Valuations Version 3C” (forthcoming
tions.                                                       1989, provides generally that the value of       2009) will contain a complete set of actuar-
                                                             an annuity, an interest for life or a term of    ial tables that include factors not contained
SUMMARY: This document contains reg-                         years, and a remainder or reversionary in-       in the temporary regulations (for example,
ulations relating to the use of actuarial                    terest is to be determined under tables pub-     annuity and life interest factors). These
tables in valuing annuities, interests for                   lished by the Secretary by using an inter-       publications will be available beginning
life or terms of years, and remainder or                     est rate (rounded to the nearest two-tenths      May 1, 2009, at no charge, electronically
reversionary interests. These regulations                    of one percent) equal to 120 percent of the      via the IRS Internet site at www.irs.gov.
will affect the valuation of inter vivos                     Federal midterm rate in effect under sec-            The following chart summarizes the ap-
and testamentary transfers of interests de-                  tion 1274(d)(1) for the month in which the       plicable interest rates and the citations to
pendent on one or more measuring lives.                      valuation date falls. Section 7520(c)(3) di-     textual materials and tables for the various
These regulations are necessary because                      rected the Secretary to issue tables not later   periods covered under the current regula-
section 7520(c)(3) directs the Secretary to                  than December 31, 1989, utilizing the then       tions:
update the actuarial tables to reflect the                   most recent mortality experience. There-
most recent mortality experience avail-                      after, the Secretary is directed to revise
able. The text of the temporary regulations                  these tables not less frequently than once
also serves as the text of the proposed                      each 10 years to take into account the most
regulations (REG–107845–08) set forth                        recent mortality experience available as of
in the notice of proposed rulemaking on                      the time of the revision.
this subject elsewhere in this issue of the                      These        temporary       regulations,
Bulletin.                                                    REG–107845–08, incorporate revised Ta-

2009–20 I.R.B.                        
To top