Contents

VALUATION OF PARTIAL INTERESTSyears (including unitrust interests), remainders, and reversions is their presentvalue. 25 Valuations in connection with transfers to pooled income funds are thesubject of separate regulations, 26 as are transfers after that date to charitableremainder trusts. 27These regulations discuss the two components of valuation. 28 These componentsare the monthly interest rate 29 and the mortality component. The latterreflects the mortality data most recently available from the U.S. census. As newmortality data becomes available after each decennial census, the mortality componentis revised and updated tables are published. 30 The mortality componenttable 31 is contained in the estate tax regulations. 32The actuarial factors for determining these values (present values) are includedin tables in the regulations or in IRS publications. 33 If a special factor is required tovalue an interest, the IRS will furnish the factor upon a request for a ruling. 34The following tables are in the regulations: 35• Table S—used in determining the present value of a single-life remainderinterest in a pooled income fund. 36• Table D (actuarial factors used in determining the present value of aremainder interest postponed for a term of years), Table U(1) (actuarialfactors for one life), and Table F (payout factors)—used in determining thepresent value of a remainder interest in a charitable remainder unitrust. 37• Table S (actuarial factors for one life), Table B (actuarial factors used indetermining the present value of an interest for a term of years), Table K(annuity end-of-interval adjustment factors), Table J (term-certain annuitybeginning-of-interval adjustment factors), and Table 90CM (mortalitycomponents)—used in determining the present value of annuities, lifeestates, remainders, and reversions. 38The following tables are in separate publications: 39• Tables of valuation factors and examples that show how to compute othervaluation factors, used in determining the present value of annuities, life25 Id. See also Reg. §§ 1.7520-1(c), 1.7520-2(a)(1).26 These separate regulations are cross-referenced in Reg. § 1.7520-1(a)(2). See § 13.11.27 These separate regulations are cross-referenced in Reg. § 1.7520-1(a)(3). See § 12.10.28 Reg. § 1.7520-1(b).29 See § 11.1.30 Reg. § 1.7520-1(b)(2). Thus, in 2000, the IRS issued final regulations (T.D. 8886), updating the actuarial tables,based on data compiled from the 1990 census, used in valuing annuities, interests for life or terms ofyears, and remainder or reversionary interests.31 Table 80CNSMT.32 Reg. § 20.2031-7(d).33 Reg. § 1.7520-1(c).34 Id. A request for a ruling must comply with the instructions for requesting a ruling (the most recent version isin Rev. Proc. 2004-1, 2004-1 I.R.B. 1), as well as Reg. §§ 601.201 and 601.601(d)(2)(ii)(b), and must includepayment of the requisite user fee.35 Reg. § 1.7520-1(c)(1).36 Reg. § 1.642(c)-6(e)(6).37 Reg. § 1.664-4(e)(6).38 Reg. § 20.2031-7(d)(6).39 Reg. § 1.7520-1(c)(2). 398