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T.D. 9448, under Section 7520, provides 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 of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The regulations are unnecessary because Section 7520(c)(3) directs the Secretary to update the actuarial tables to reflect the most recent mortality experience available.
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.
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