# Bulletin No. 1999–20 > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3A171a4bc5a0e6b315 ## Record - **Collection:** Agency decision - **Document type:** Agency decision ## Text Internal Revenue bulletin Bulletin No. 1999–20 May 17, 1999 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 Rev. Rul. 99–23, page 3. Start-up expenditures, business expenses, capital expenditures. Guidance is provided on the types of expenditures that will qualify as investigatory costs that are eligible for amortization as start-up expenditures under section 195 of the Code when a taxpayer acquires the assets of an active trade or business. ESTATE AND GIFT TAX T.D. 8819, page 5. REG–103851–99, page 93. Use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. Proposed, temporary and final regulations under section 7520 of the Code relate to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. ADMINISTRATIVE REG–106004–98, page 77. Proposed regulations under section 355 of the Code relate to recognition of gain on certain distributions of stock or securities of a controlled corporation. A public hearing is scheduled for September 21, 1999. Finding Lists begin on page 97. Department of the Treasury Internal Revenue Service Notice 99–23, page 73. This notice effects interim revisions to Schedule P of Form 1120–FSC (1998) and its instructions, filed by foreign sales corporations. The notice also solicits public comments by June 30, 1999, on certain proposed revisions to Schedule P for subsequent tax years. Notice 99–24, page 74. This notice informs taxpayers of the intent of Treasury and the Service to include in final regulations a one-year extension of the time for foreign sales corporations and their related suppliers to file grouping redeterminations under the transition rule for Temp. Treas. Reg. section 1.925(a)– 1T(c)(8)(i). Notice 99–25, page 75. The Service will extend the effective date of the nonresident alien withholding regulations under section 1441 of the Code that were published in T.D. 8734, 1997–2 C.B. 109. As extended, those regulations will apply to certain payments made to foreign persons after December 31, 2000. Announcement 99–53, page 95. This document contains a correction to Notice 99–18, 1999–16 I.R.B. 4, in which the underlying calculation given to determine the nonconventional source fuel credit amount contained an erroneous number. However, the amount of the credit itself was not erroneous. Mission of the Service and by applying the tax law with integrity and fairness to all. Provide America’s taxpayers top quality service by helping them understand and meet their tax responsibilities 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 Conventions, 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 consolidated semiannually into Cumulative Bulletins, which are sold on a single-copy basis. dures 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.—1986 Code. This part includes rulings and decisions based on provisions of the Internal Revenue Code of 1986. It is the policy of the Service to publish in the Bulletin all substantive rulings necessary to promote a uniform application of the tax laws, including all rulings that supersede, revoke, modify, or amend any of those previously published in the Bulletin. All published rulings apply retroactively unless otherwise indicated. Procedures relating solely to matters of internal management are not published; however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. Part II.—Treaties and Tax Legislation. This part is divided into two subparts as follows: Subpart A, Tax Conventions, and Subpart B, Legislation 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 Rulings. Bank Secrecy Act Administrative Rulings are issued by the Department of the Treasury’s Office of the Assistant Secretary (Enforcement). 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. Part IV.—Items of General Interest. This part includes notices of proposed rulemakings, disbarment and suspension lists, and announcements. 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 proce- The first 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 first Bulletin of the succeeding semiannual period, respectively. The contents 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. 2 Part I. Rulings and Decisions Under the Internal Revenue Code of 1986 Section 162.—Trade or Business Expenses 26 CFR 1.162–1: Business expenses. What types of expenditures will qualify as investigatory costs that are eligible for amortization as start-up expenditures under section 195 of the Code when a taxpayer acquires the assets of an active trade or business? See Rev. Rul. 99–23, on this page. Section 195.—Start-up Expenditures (Also sections 162, 263; 26 CFR 1.162–1, 1.263(a)–1) Start-up expenditures, business expenses, capital expenditures. Guidance is provided on the types of expenditures that will qualify as investigatory costs that are eligible for amortization as start-up expenditures under section 195 of the Code when a taxpayer acquires the assets of an active trade or business. Rev. Rul. 99–23 ISSUE When a taxpayer acquires the assets of an active trade or business, which expenditures will qualify as investigatory costs that are eligible for amortization as startup expenditures under § 195 of the Internal Revenue Code? FACTS Situation 1 In April 1998, corporation U hired an investment banker to evaluate the possibility of acquiring a trade or business unrelated to U’s existing business. The investment banker conducted research on several industries and evaluated publicly available financial information relating to several businesses. Eventually, U narrowed its focus to one industry. The investment banker evaluated several businesses within the industry, including corporation V and several of V’s competitors. The investment banker then commissioned appraisals of V’s assets and an in-depth review of V’s books and records in order to determine a fair acquisition price. On November 1999–20 I.R.B. 1,1998, U entered into an acquisition agreement with V to purchase all the assets of V. U did not prepare and submit a letter of intent, or any other preliminary agreement or written document evidencing an intent to acquire V prior to executing the acquisition agreement. Situation 2 In May 1998, corporation W began searching for a trade or business to acquire. In anticipation of finding a suitable target to acquire, W hired an investment banker to evaluate three potential businesses and a law firm to begin drafting regulatory approval documents for a target. Eventually, W decided to purchase all the assets of corporation X. W and X entered into an acquisition agreement on December 1, 1998. Situation 3 In June 1998, corporation Y hired a law firm and an accounting firm to assist in the potential acquisition of corporation Z by performing certain services that the parties labeled as “preliminary due diligence.” These “due diligence” services included conducting research on Z’s industry (including information relating to competitors of Z), and analyzing financial projections for Z for 1998 and 1999. In September 1998, at Y’s request, the law firm prepared and submitted a letter of intent to Z. The offer contained in the letter of intent resulted from prior discussions between Y and Z, and specifically stated that a binding commitment with respect to the proposed transaction would result only upon execution of an acquisition agreement. Thereafter, the law firm and accounting firm continued to provide services labeled as “due diligence,” including a review of Z’s internal documents relating to insurance policies, employee agreements, and lease agreements, an indepth review of Z’s books and records, and preparation of an acquisition agreement. On October 10, 1998, Y entered into an acquisition agreement with Z to purchase all the assets of Z. In each of the three situations, the trades or businesses of the targets are active trades or businesses unrelated to the trades or businesses of U, W, and Y. U, 3 W, and Y each use an accrual method of accounting and a calendar taxable year. Each of the acquisition agreements entered into by U, W, and Y were subject to customary conditions of closing. Finally, U, W, and Y each completed the acquisitions in 1998 and timely elected on their 1998 federal income tax returns to amortize start-up expenditures over a period of not less than 60 months under § 195(b). LAW AND ANALYSIS Section 195(a) provides that, except as otherwise provided in § 195, no deduction is allowed for start-up expenditures. Section 195(b) provides that start-up expenditures may, at the election of the taxpayer, be treated as deferred expenses that are allowed as a deduction prorated equally over a period of not less than 60 months (beginning with the month in which the active trade or business begins). Section 195(c)(1) defines “start-up expenditure,” in part, as any amount (A) paid or incurred in connection with investigating the creation or acquisition of an active trade or business, and (B) which, if paid or incurred in connection with the operation of an existing active trade or business (in the same field as the trade or business referred to in subparagraph (A)), would be allowable as a deduction for the taxable year in which paid or incurred. Thus, in order to qualify as start-up expenditures under § 195(c)(1), a taxpayer’s “investigatory costs” must satisfy the requirements in both §§ 195(c)(1)(A) and (B). In addition, the term “start-up expenditure” does not include any amount with respect to which a deduction is allowable under §163(a), 164, or 174. Sections 162 and 1.162–1(a) of the Income Tax Regulations allow a deduction for all the ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business. Courts generally have construed § 162 as containing five conditions that an expenditure must meet to qualify for deduction. The expenditure must be (1) an expense, (2) ordinary, (3) necessary, (4) paid or incurred during the taxable year, and (5) made to carry on a trade or business. See Commissioner v. Lincoln Savings and Loan Ass’n., 403 U.S. 345 (1971). May 17, 1999 Sections 263 and 1.263(a)–1(a) provide that no deduction is allowed for any amounts paid out for new buildings or for permanent improvements or betterments made to increase the value of any property or estate. Section 1.263(a)–2(a) provides that capital expenditures include the cost of acquisition, construction, or erection of buildings, machinery and equipment, furniture and fixtures, and similar property having a useful life substantially beyond the taxable year. Through provisions such as §§ 162(a) and 263(a), the Code generally endeavors to match expenses with the revenues of the taxable period to which the expenses are properly attributable, thereby resulting in a more accurate calculation of net income for tax purposes. See, e.g., INDOPCO, Inc. v. Commissioner, 503 U.S. 79 (1992). In describing the law prior to § 195, Congress explained that “investigatory expenses,” which were “costs incurred in seeking and reviewing prospective businesses prior to reaching a decision to acquire or enter any business,” normally were not deductible because they were not incurred in carrying on a trade or business within the meaning of § 162. See H.R. Rep. No. 1278, 96th Cong., 2d Sess. 9 (1980) (House Report); S. Rep. No. 1036, 96th Cong., 2d Sess 10 (1980) (Senate Report). The “carrying on a trade or business” requirement was not met where investigatory expenses were incurred by a taxpayer who was not yet carrying on any trade or business, or where a taxpayer was carrying on a trade or business but incurred costs to investigate the creation or acquisition of another, unrelated trade or business. Id. However, a taxpayer incurring costs to investigate the expansion of an existing business generally could deduct those costs under § 162, assuming the other requirements of that section were met. This disparity in the tax treatment of investigatory expenses resulting from the “carrying on a trade or business” requirement discouraged taxpayers from investigating the creation or acquisition of new trades or businesses. Section 195 was enacted, in part, to minimize this disparity and thereby encourage formation of new businesses by providing an amortization deduction for eligible investigatory expenses. May 17, 1999 Accordingly, under § 195(c)(1)(B), expenditures described in § 195(c)(1)(A) that are incurred before the establishment of an active business are deemed to be paid or incurred in the operation of an existing active trade or business (in the same field as the business that the taxpayer is investigating whether to create or acquire), i.e., they are deemed to satisfy the carrying on a trade or business requirement. However, because § 195(c)(1)(B) also requires that an expenditure described in § 195(c)(1)(A) be allowable as a deduction for the taxable year in which paid or incurred, the expenditure still must meet all the other requirements of §162. Thus, the expenditure must be an ordinary expense under § 162, and not a capital expenditure, to be a start-up expenditure under § 195. “Section 195 did not create a new class of deductible expenditures for existing businesses. . . . [I]n order to qualify under section 195(c)(1)(B), an expenditure must be one that would have been allowable as a deduction by an existing trade or business when it was paid or incurred.” FMR Corp. v. Commissioner, 110 T.C. No. 30 (June 18, 1998). See also §§ 161 and 261 (deductions are allowed, subject to capitalization provisions). Whether an expenditure is an ordinary expense or is capital in nature is a question of fact that depends on the context in which the expenditure is incurred. See Commissioner v. Idaho Power Co., 418 U.S. 1 (1974); Deputy v. duPont, 308 U.S. 488 (1940); Welch v. Helvering, 290 U.S. 111 (1933). The legislative history of § 195 provides the following guidance regarding whether an expenditure is an ordinary investigatory cost that is an eligible start-up expenditure, or a capital acquisition cost: Eligible expenses consist of investigatory costs incurred prior to reaching a final decision to acquire or enter that business. These costs include expenses incurred for the analysis or survey of potential markets, products, labor supply, transportation facilities, etc. Start-up expenditures eligible for amortization do not include any amount with respect to which a deduction would not be allowed to an existing trade or business for the taxable year in which the expenditure was paid or incurred. . . . In addition, the amortization election for start-up expenditures does not apply to amounts paid or incurred as part of the acquisition cost of a trade or business. Also, start-up expenditures do not include amounts paid or incurred for the acquisition of property to be held for 4 sale or property which may be depreciated or amortized based on its useful life. . . Whether an amount is consideration paid to acquire a business depends upon the facts and circumstances of the situation. House Report at pages 10–11; Senate Report at pages 11–12. Rev. Rul. 77–254, 1977–2 C.B. 63, which is specifically referenced by the legislative history of § 195 (House Report at 9, Senate Report at 10), considers which costs incurred in the potential acquisition of a new business are capital acquisition costs for purposes of §§ 165 and 263. That ruling provides that expenses incurred in the course of a general search for, or an investigation of, a business that relate to the decisions whether to purchase a business and which business to purchase are investigatory costs. However, once a taxpayer has focused on the acquisition of a specific business, expenses that are related to an attempt to acquire that business are capital in nature. Thus, the “final decision” referred to in the legislative history of § 195 is the point at which a taxpayer makes its decision whether to acquire a business, and which business to acquire, rather than the point at which a taxpayer and seller are legally obligated to complete the transaction. Courts have long held that legal, brokerage, accounting, appraisal, and similar costs incurred to acquire a capital asset are capital expenditures under § 263. Woodward v. Commissioner, 397 U.S. 572 (1970) (when property is acquired by purchase, nothing is more clearly a part of the process of acquisition than the establishment of a purchase price); United States v. Hilton Hotels Corp., 397 U.S. 580 (1970); Beneficial Industrial Loan Corp. v. Handy, 16 F. Supp. 110, 112 (D. Del. 1936), aff ’d, 92 F.2d 74 (3d Cir. 1937); Rev. Rul. 73–580, 1973–2 C.B. 86. For example, in Ellis Banking Corp. v. Commissioner, T.C. Memo. 1981–123, aff ’d in part & rem’d in part, 688 F.2d 1376 (11th Cir. 1982), the taxpayer incurred expenses for office supplies, filing fees, travel, and accounting services in connection with its examination of target’s books and records. The examination was performed pursuant to an acquisition agreement for the purchase of target’s stock that was contingent on several terms and conditions, such as regulatory approval. The Tax Court concluded that the 1999–20 I.R.B. expenses were nondeductible capital expenditures incurred in the acquisition of a capital asset. The Court of Appeals for the Eleventh Circuit substantially affirmed, noting that the requirement that costs be capitalized extends beyond the price payable to include any costs incurred by the buyer in connection with the purchase, such as appraisals of the property or the costs of meeting any conditions of sale. Accordingly, expenditures incurred in the course of a general search for, or an investigation of, an active trade or business, i.e., expenditures paid or incurred in order to determine whether to enter a new business and which new business to enter (other than costs incurred to acquire capital assets that are used in the search or investigation), are investigatory costs that are start-up expenditures under § 195. Alternatively, costs incurred in the attempt to acquire a specific business are capital in nature and thus, are not start-up expenditures under § 195. The nature of the cost must be analyzed based on all the facts and circumstances of the transaction to determine whether it is an investigatory cost incurred to facilitate the whether and which decisions, or an acquisition cost incurred to facilitate consummation of the acquisition. The label that the parties use to describe the cost and the point in time at which the cost is incurred do not necessarily determine the nature of the cost. In Situation 1, an examination of the nature of the costs incurred indicates that U made its decision to acquire V after the investment banker conducted research on several industries and evaluated publicly available financial information. The costs incurred to conduct industry research and review public financial information are typical of the costs related to a general investigation. Accordingly, the costs incurred to conduct industry research and to evaluate publicly available financial information are investigatory costs eligible for amortization as start-up expenditures under § 195. However, the costs relating to the appraisals of V’s assets and an indepth review of V’s books and records to establish the purchase price facilitate consummation of the acquisition, and thus, are capital acquisition costs. The costs incurred to evaluate V and V’s competitors also may be investigatory costs, but only 1999–20 I.R.B. to the extent they were incurred to assist U in determining whether to acquire a business and which business to acquire. If the evaluation of V and V’s competitors occurred after U had made its decision to acquire V (for example, in an effort to establish the purchase price for V), such evaluation costs are capital acquisition costs. In Situation 2, the costs incurred to evaluate potential businesses are investigatory costs eligible for amortization as start-up expenditures under § 195 to the extent they relate to the whether and which decisions. However, the costs incurred to draft regulatory approval documents prior to the time W decided to acquire X are not start-up expenditures under § 195. The costs related to such activities, even if the activities occurred during the period W is engaged in a general search for a business, were not incurred in order to investigate whether to acquire a business and which business to acquire, but rather to facilitate an acquisition. In Situation 3, an examination of the nature of the costs incurred by Y indicates that Y made its decision to acquire Z in September 1998, around the time that Y instructed the law firm to prepare and submit the letter of intent. The costs related to the “preliminary due diligence” services provided prior to that time (including the costs of conducting research on Z’s industry and in reviewing financial projections of Z) are typical of the costs incurred during an investigation to determine whether to acquire a new business and which new business to acquire. Thus, these costs are investigatory costs that are eligible for amortization as start-up expenditures under § 195. The costs related to “due diligence” services provided after that time, however, relate to the attempt to acquire the business and must be capitalized under § 263 as acquisition costs. Thus, the “due diligence” costs incurred to review T’s internal documents, books and records, and to draft the acquisition agreements are not eligible for amortization under § 195. HOLDING Expenditures incurred in the course of a general search for, or investigation of, an active trade or business in order to determine whether to enter a new business 5 and which new business to enter (other than costs incurred to acquire capital assets that are used in the search or investigation) qualify as investigatory costs that are eligible for amortization as start-up expenditures under § 195. However, expenditures incurred in the attempt to acquire a specific business do not qualify as start-up expenditures because they are acquisition costs under § 263. The nature of the cost must be analyzed based on all the facts and circumstances of the transaction to determine whether it is an investigatory cost incurred to facilitate the whether and which decisions, or an acquisition cost incurred to facilitate consummation of an acquisition. DRAFTING INFORMATION The principal author of this revenue ruling is Susie K. Bird of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue ruling contact Ms. Bird on (202) 622-4950 (not a toll-free call). Section 7520.—Valuation Tables 26 CFR 20.7520–1: Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests. T.D. 8819 DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Parts 1, 20, and 25 Use of Actuarial Tables in Valuing Annuities, Interests for Life or Terms of Years, and Remainder or Reversionary Interests AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final and temporary regulations. SUMMARY: This document contains regulations relating to the use of actuarial tables in valuing annuities, interests for life or terms of years, and remainder or reversionary interests. These regulations are necessary because section 7520(c)(3) directs the Secretary to update the actuar- May 17, 1999 ial tables to reflect the most recent mortality experience available. These regulations will effect the valuation of inter vivos and testamentary transfers of interests dependent on one or more measuring lives. The text of the temporary regulations also serves as the text of the proposed regulations REG–103851–99, page 93 in this Bulletin. DATES: These regulations are effective May 1, 1999. FOR FURTHER INFORMATION CONTACT: Concerning the regulations, William L. Blodgett, (202) 622-3090 (not a toll-free number). SUPPLEMENTARY INFORMATION: Background This document contains amendments to the regulations revising certain tables used for the valuation of partial interests in property under section 7520 of the Internal Revenue Code of 1986 (Code) to reflect the most recent mortality experience available. In General Section 7520, effective for transfers for which the valuation date is after April 30, 1989, provides that the value of an annuity, an interest for life or a term of years, and a remainder or reversionary interest is to be determined under tables published by the Internal Revenue Service based on a discount rate (rounded to the nearest two-tenths of one percent) equal to 120 percent of the applicable Federal mid-term rate in effect under section 1274(d)(1) for the month in which the valuation date falls. Section 7520(c)(3) directed the Secretary to issue tables not later than December 31, 1989, utilizing the then most recent mortality experience. Thereafter, the Secretary is directed to revise the tables used in valuing interests dependent on mortality experience not less frequently than once each 10 years to take into account the most recent mortality experience available as of the time of the revision. These regulations incorporate revised Table S (Single Life Remainder Factors) and Table U(1) (Unitrust Single Life Remainder Factors) based on data compiled from the 1990 census as set forth in Life Table 90CM, and make conforming amendments to various sections to reflect the revised tables. The current tables are moved to sections containing actuarial material for historical reference. Table B, Table D, Tables F(4.2) through F(14.0), Table J, and Table K, which are not based on mortality experience, are not changed. Internal Revenue Service Publications 1457 “Actuarial Values, Book Aleph” (forthcoming 1999), 1458 “Actuarial Values, Book Beth” (forthcoming 1999), and 1459 “Actuarial Values, Book Gimel” (forthcoming 1999) will contain a complete set of actuarial tables that include factors not contained in the regulations (for example, annuity and life interest factors). Although not available on May 1, 1999, IRS anticipates these publications will be available by July 1, 1999. These publications will be available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. The following chart summarizes the applicable interest rates and the citations to textual materials and tables for the various periods covered under the regulations: Cross Reference to Regulation Sections Valuation Period Interest Rate Regulation Section Table Section 642: Valuation, in general before 01/01/52 01/01/52 – 12/31/70 01/01/71 – 11/30/83 12/01/83 – 04/30/89 05/01/89 – 04/30/99 after 04/30/99 — 4% 3.5% 6% 10% §7520 §7520 1.642(c)–6 1.642(c)–6A(a) 1.642(c)–6A(b) 1.642(c)–6A(c) 1.642(c)–6A(d) 1.642(c)–6A(e) 1.642(c)–6T(e) Table G Table S (5/1/89 – 4/30/99) Table S (after 04/30/99) Section 664: Valuation, in general before 01/01/52 01/01/52 – 12/31/70 01/01/71 – 11/30/83 12/01/83 – 04/30/89 05/01/89 – 04/30/99 after 04/30/99 — 4% 3.5% 6% 10% §7520 §7520 1.664–4 1.664–4A(a) 1.664–4A(b) 1.664–4A(c) 1.664–4A(d) 1.664–4A(e) 1.664–4T(e) 1.664–4(e) Section 2031: Valuation, in general before 01/01/52 01/01/52 – 12/31/70 01/01/71 – 11/30/83 — 4% 3.5% 6% 20.2031–7 20.2031–7A(a) 20.2031–7A(b) 20.2031–7A(c) May 17, 1999 6 Table E, Table F(1) Table U(1) (5/1/89 – 4/30/99) Table U(1) (after 04/30/99) Table D and Tables F(4.2) – F(14.0) 1999–20 I.R.B. Cross Reference to Regulation Sections (Continued) Valuation Period Interest Rate Regulation Section 12/01/83 – 04/30/89 05/01/89 – 04/30/99 10% §7520 20.2031–7A(d) 20.2031–7A(e) after 04/30/99 §7520 20.2031–7T(d) Table 20.2031–7(d) Section 2512: Valuation, in general before 01/01/52 01/01/52 – 12/31/70 01/01/71 – 11/30/83 12/01/83 – 04/30/89 05/01/89 – 04/30/99 after 04/30/99 Effective Dates These regulations are applicable in the case of annuities, interests for life or terms of years, and remainder or reversionary interests created after April 30, 1999. Transitional Rules The regulations provide certain transitional rules intended to alleviate any adverse consequences resulting from the proposed regulatory change. For gift tax purposes, if the valuation date of a transfer is after April 30, 1999, but before July 1, 1999, the donor may determine the value of the gift (and/or any applicable charitable deduction) under tables based on either Life Table 80CNSMT or Table 90CM (at the donor’s option). Similarly, for estate tax purposes, if the decedent dies after April 30, 1999, but before July 1, 1999, the value of any interest (and/or any applicable charitable deduction) may be determined under tables based on either Table 80CNSMT or Table 90CM, at the option of the decedent’s executor. However, the section 7520 interest rate utilized is the appropriate rate for the month in which the valuation date occurs. In accordance with this transitional rule and those contained in §§1.7520–2(a)(2), 20.7520–2(a)(2) and 25.7520–2(a)(2), in cases involving a charitable deduction, if the valuation date occurs after April 30, 1999, and before July 1, 1999, and the executor or donor elects under section 7520(a) to use the section 7520 interest rate for March 1999 or April 1999, then 1999–20 I.R.B. Table A, Table B, Table LN Table S (5/1/89 – 4/30/99) Life Table 80CNSMT Table S (after 04/30/99) and Life Table 90CM Table B, Table J, Table K, 25.2512–5 25.2512–5A(a) 25.2512–5A(b) 25.2512–5A(c) 25.2512–5A(d) 25.2512–5A(e) 25.2512–5T(d) 4% 3.5% 6% 10% §7520 §7520 the mortality experience contained in 80CNSMT must be used. If the executor or donor uses the section 7520 interest rate for May 1999 or for June 1999, then the tables based on either Table 80CNSMT or Table 90CM may be used. However, if the valuation date occurs after June 30, 1999, the executor or donor must use the new mortality experience contained in Table 90CM even if a prior month interest rate election under section 7520(a) is made. In addition, for estate tax purposes, the estate of a mentally incompetent decedent may elect to value the property interest included in the gross estate under the mortality table and interest rate in effect at the time the decedent became mentally incompetent or the mortality table and interest rate in effect on the decedent’s date of death if the decedent was under a mental incapacity that existed on May 1, 1999, and continued uninterrupted until the decedent’s death, or the decedent died within 90 days of regaining competency after April 30, 1999. entities, the Regulatory Flexibility Act (5 U.S.C. chapter 6) does not apply. Therefore, a Regulatory Flexibility Analysis is not required. Pursuant to section 7805(f) of the Internal Revenue Code, these regulations will be submitted to the Chief Counsel for Advocacy of the Small Business Administration for comment on its impact on small business. Special Analysis Paragraph 1. The authority citation for part 1 is amended by adding entries in numerical order to read in part as follows: Authority: 26 U.S.C. 7805 * * * Section 1.170A–12 also issued under 26 U.S.C. 170(f)(4). * * * Section 1.642(c)–6 also issued under 26 U.S.C. 642(c)(5). Section 1.642(c)–6T also issued under 26 U.S.C. 642(c)(5). Section 1.642(c)–6A also issued under 26 U.S.C. 642(c)(5). It has been determined that this Treasury decision is not a significant regulatory action as defined in EO 12866. Therefore, a regulatory assessment is not required. It also has been determined that section 553(b) of the Administrative Procedure Act (5 U.S.C. chapter 5) does not apply to these regulations, and because these regulations do not impose a collection of information requirement on small 7 Drafting Information The principal author of these regulations is William L. Blodgett, Office of Assistant Chief Counsel (Passthroughs and Special Industries), IRS. However, other personnel from the IRS and Treasury Department participated in their development. * * * * * Adoption of Amendments to the Regulations Accordingly, 26 CFR parts 1, 20, and 25 are amended as follows: PART 1—INCOME TAXES May 17, 1999 Section 1.664–1 also issued under 26 U.S.C. 664(a). Section 1.664–2 also issued under 26 U.S.C. 664(a). Section 1.664–3 also issued under 26 U.S.C. 664(a). Section 1.664–4 also issued under 26 U.S.C. 664(a). Section 1.664–4T also issued under 26 U.S.C. 664(a). Section 1.664–4A 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. Section 1.170A–6 is amended by revising paragraph (c)(5), Example (2)(b) introductory text to read as follows: §1.170A–6 Charitable contributions in trust. * * * * * (c) * * * (5) * * * Example 2. * * * (b) The section 7520 rate at the time of 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 90CM of §20.2031–7T (or, for prior periods, the tables set forth under §20.2031– 7A) of this chapter. (3) The following example illustrates the provisions of this paragraph (b): Example. A, who is 62, donates to Y University a remainder interest in a personal residence, consisting of a house and land, subject to a reserved life estate in A. At the time of the gift, the land has a value of $30,000 and the house has a value of $100,000 with an estimated useful life of 45 years, at the end of which the value of the house is expected to be $20,000. The portion of the property considered to be depreciable is $80,000 (the value of the house ($100,000) less its expected value at the end of 45 years ($20,000)). The portion of the property considered to be nondepreciable is $50,000 (the value of the land at the time of the gift ($30,000) plus the expected value of the house at the end of 45 years ($20,000)). At the time of the gift, the interest rate prescribed under section 7520 is 8.4 percent. Based on an interest rate of 8.4 percent, the remainder fac- May 17, 1999 (a) through (b)(1) [Reserved] For further guidance see §1.170A–12(a) through (b)(1). (b)(2) Computation of depreciation factor after April 30, 1999. If the valuation of the remainder interest in depreciable property is dependent upon the continuation of one life, a special factor must be used. The factor determined under this paragraph (b)(2) is carried to the fifth decimal place. The special factor is to be computed on the basis of the interest rate and life contingencies prescribed in §20.2031–7T (or for certain prior periods, §20.2031–7A) of this chapter (Estate Tax Regulations) 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 after April 30, 1999, special factors for determining the present value of a remainder interest following one life and an example describing the computation is contained in Internal Revenue Service Publication 1459, “Actuarial Values, Book Gimel,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Otherwise, in the case of the valuation of a remainder interest following one life, the special factor may be obtained through use of the following formula: tor for $1.00 prescribed in §20.2031–7T(d) of this chapter for a person age 62 is 0.27925. The value of the nondepreciable remainder interest is $13,962.50 (0.27925 times $50,000). The value of the depreciable remainder interest is $16,148.80 (0.20186, computed under the formula described in paragraph (b)(2) of this section, times $80,000). Therefore, the value of the remainder interest is $30,111.30. (d) and (e) [Reserved]. For further guidance, see §1.642(c)–6T(d) and (e). (f) Effective dates. This section applies after April 30, 1989, and before May 1, 1999. Par. 5. Section 1.642(c)–6T is added to read as follows: (c) through (e) [Reserved]. For further guidance see §1.170A–12(c) through (e). Par. 4. Section 1.642(c)–6 is amended as follows: 1. Revise the section heading. 2. Paragraph (d) is removed. 3. Paragraph (e) is redesignated as paragraph (e) of §1.642(c)–6A. 4. New paragraphs (d) and (e) are added. 5. Paragraph (f) is revised. The revisions and addition read as follows: §1.642(c)–6T Valuation of a remainder interest in property transferred to a pooled income fund (temporary). the transfer was 6.0 percent. By reference to Table F(6.0) in §1.664–4(e)(6), the adjusted payout rate is 4.717% (5% ⫻ 0.943396). The present value of the reversion is $6,473.75, computed by reference to Table D in §1.664–4(e)(6), as follows: * * * * * 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). §1.642(c)–6 Valuation of a remainder interest in property transferred to a pooled income fund. (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 after April 30, 1999, is determined under paragraph (e) of this section. The present value of the remainder interest in property transferred to a pooled income fund for which the valuation date is before May 1, 1999, is determined under the following sections: * * * * * 8 1999–20 I.R.B. Valuation Dates After Before — 12-31-51 2-31-70 11-30-83 04-30-89 01-01-52 01-01-71 2-01-83 05-01-89 05-01-99 Applicable Regulations 1.642(c)–6A(a) 1.642(c)-6A(b) 1.642(c)–6A(c) 1.642(c)–6A(d) 1.642(c)–6A(e) (e) Present value of the remainder interest in the case of transfers to pooled income funds for which the valuation date is after April 30, 1999—(1) In general. In the case of transfers to pooled income funds for which the valuation date is after April 30, 1999, the present value of a remainder interest is determined under this section. See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). The present value of a remainder interest that is dependent on the termination of the life of one individual is computed by the use of Table S in paragraph (e)(6) of this section. For purposes of the computations under this section, the age of an individual is the age at the individual’s nearest birthday. (2) Transitional rules for valuation of transfers to pooled income funds. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor. (ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a pooled income fund for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of the remainder interest under this section is determined by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§1.75201(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), at the option of the 1999–20 I.R.B. donor or the decedent’s executor, as the case may be. (iii) For purposes of paragraphs (e)(2)(i) and (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(6) of this section or §1.642(c)–6A(e)(5), 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 (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables). (3) Present value of a remainder interest. The present value of a remainder interest in property transferred to a pooled income fund is computed on the basis of— (i) Life contingencies determined from the values of lx that are set forth in Table 90CM in §20.2031–7T(d)(7) of this chapter (Estate Tax Regulations) (See § 20.2031–7A of this chapter for certain prior periods); and (ii) Discount at a rate of interest, compounded annually, equal to the highest yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. For purposes of this paragraph (e), the yearly rate of return of a pooled income fund is determined as provided in §1.642(c)–6(c) unless the highest rate of return is deemed to be the rate described in paragraph (e)(4) of this section for funds in existence less than 3 taxable years. For purposes of this paragraph (e)(3)(ii), the first taxable year of a pooled income fund is considered a taxable year even though the taxable year consists of less than 12 months. However, appropriate adjustments must be made to annualize the rate of return earned by the fund for that period. Where it appears from the facts and circumstances that the highest yearly rate of return of the fund for the 3 taxable years immediately preceding the taxable year in which the transfer of property is made has been purposely manipulated to be substantially less than the rate of return that would otherwise be reasonably anticipated with the purpose of ob- 9 taining an excessive charitable deduction, that rate of return may not be used. In that case, the highest yearly rate of return of the fund is determined by treating the fund as a pooled income fund that has been in existence for less than 3 preceding taxable years. (4) Pooled income funds in existence less than 3 taxable years. If a pooled income fund has been in existence less than 3 taxable years immediately preceding the taxable year in which the transfer is made to the fund and the transfer to the fund is made after April 30, 1989, the highest rate of return is deemed to be the interest rate (rounded to the nearest two-tenths of one percent) that is 1 percent less than the highest annual average of the monthly section 7520 rates for the 3 calendar years immediately preceding the calendar year in which the transfer to the pooled income fund is made. The deemed rate of return for transfers to new pooled income funds is recomputed each calendar year using the monthly section 7520 rates for the 3year 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. The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(6) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based (See §1.642(c)–6A for certain prior periods). The tables in paragraph (e)(6) of this section include factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in the tables in paragraph (e)(6) of this section is contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Values, Book Aleph,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, May 17, 1999 DC 20402. For other situations, see §1.642(c)-6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor. This paragraph (e)(5) may be illustrated by the following example: tains a life income interest in the property. The highest yearly rate of return earned by the fund for its 3 preceding taxable years is 9.47 percent. In Table S, the remainder factor opposite 55 years under 9.4 percent is .17449 and under 9.6 percent is .17001. The present value of the remainder interest is $17,292.00, computed as follows: Factor at 9.4 percent for age 55 . . . . . . . .17449 Factor at 9.6 percent for age 55 . . . . . . . .17001 Difference . . . . . . . . . . . . . . . . . . . . . . . .00448 Interpolation adjustment: 9.47% – 9.4% 0.2% x Example. A, who is 54 years and 8 months, transfers $100,000 to a pooled income fund, and re- = = x .00448 .00157 Factor at 9.4 percent for age 55 . . . . . . . .17449 Less: Interpolation adjustment . . . . . . . .00157 Interpolated factor . . . . . . . . . . . . . . . . . .17292 Present value of remainder interest: ($100,000 3 .17292) . . . . . . . . . . . . $17,292.00 (6) Actuarial tables. In the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined by use of the following Table S: TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 0 1 2 3 4 .06752 .06137 .06325 .06545 .06784 .06130 .05495 .05667 .05869 .06092 .05586 .04932 .05088 .05275 .05482 .05109 .04438 .04580 .04752 .04944 .04691 .04003 .04132 .04291 .04469 .04322 .03620 .03737 .03883 .04048 .03998 .03283 .03388 .03523 .03676 .03711 .02985 .03079 .03203 .03346 .03458 .02721 .02806 .02920 .03052 .03233 .02487 .02563 .02668 .02791 5 6 7 8 9 .07040 .07310 .07594 .07891 .08203 .06331 .06583 .06849 .07129 .07423 .05705 .05941 .06191 .06453 .06731 .05152 .05372 .05607 .05853 .06115 .04662 .04869 .05089 .05321 .05567 .04229 .04422 .04628 .04846 .05079 .03845 .04025 .04219 .04424 .04643 .03503 .03672 .03854 .04046 .04253 .03199 .03357 .03528 .03709 .03904 .02928 .03076 .03236 .03407 .03592 10 11 12 13 14 .08532 .08875 .09233 .09601 .09974 .07734 .08059 .08398 .08748 .09102 .07024 .07331 .07653 .07985 .08322 .06392 .06683 .06989 .07304 .07624 .05829 .06104 .06394 .06693 .06997 .05326 .05587 .05862 .06146 .06435 .04877 .05124 .05385 .05655 .05929 .04474 .04709 .04957 .05214 .05474 .04114 .04336 .04572 .04816 .05064 .03790 .04002 .04226 .04458 .04694 15 16 17 18 19 .10350 .10728 .11108 .11494 .11889 .09460 .09818 .10179 .10545 .10921 .08661 .09001 .09344 .09691 .10047 .07946 .08268 .08592 .08921 .09259 .07303 .07608 .07916 .08227 .08548 .06725 .07014 .07306 .07601 .07904 .06204 .06479 .06755 .07034 .07322 .05735 .05996 .06257 .06521 .06794 .05312 .05559 .05807 .06057 .06315 .04930 .05164 .05399 .05636 .05880 20 21 22 23 24 .12298 .12722 .13159 .13613 .14084 .11310 .11713 .12130 .12563 .13014 .10417 .10801 .11199 .11612 .12043 .09610 .09976 .10354 .10748 .11160 .08881 .09228 .09588 .09964 .10357 .08220 .08550 .08893 .09250 .09625 .07622 .07935 .08260 .08601 .08958 .07078 .07375 .07685 .08009 .08349 .06584 .06866 .07160 .07468 .07793 .06135 .06403 .06682 .06975 .07284 25 26 27 28 29 .14574 .15084 .15615 .16166 .16737 .13484 .13974 .14485 .15016 .15567 .12493 .12963 .13454 .13965 .14497 .11591 .12041 .12513 .13004 .13516 .10768 .11199 .11652 .12124 .12617 .10018 .10431 .10865 .11319 .11792 .09334 .09728 .10144 .10580 .11035 .08708 .09085 .09484 .09901 .10339 .08135 .08496 .08878 .09279 .09699 .07611 .07956 .08322 .08706 .09109 May 17, 1999 10 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 30 31 32 33 34 .17328 .17938 .18568 .19220 .19894 .16138 .16728 .17339 .17972 .18627 .15048 .15618 .16210 .16824 .17460 .14047 .14599 .15171 .15766 .16383 .13129 .13661 .14214 .14790 .15388 .12286 .12799 .13333 .13889 .14468 .11510 .12004 .12520 .13058 .13618 .10796 .11272 .11769 .12289 .12831 .10138 .10597 .11076 .11578 .12102 .09532 .09974 .10435 .10920 .11426 35 36 37 38 39 .20592 .21312 .22057 .22827 .23623 .19307 .20010 .20737 .21490 .22270 .18121 .18805 .19514 .20251 .21013 .17025 .17691 .18382 .19100 .19845 .16011 .16658 .17331 .18031 .18759 .15073 .15701 .16356 .17038 .17747 .14204 .14814 .15450 .16113 .16805 .13399 .13990 .14608 .15253 .15927 .12652 .13225 .13825 .14452 .15108 .11958 .12514 .13096 .13705 .14344 40 41 42 43 44 .24446 .25298 .26178 .27087 .28025 .23078 .23915 .24782 .25678 .26603 .21805 .22626 .23478 .24360 .25273 .20620 .21425 .22262 .23129 .24027 .19516 .20305 .21125 .21977 .22860 .18487 .19259 .20062 .20898 .21766 .17527 .18282 .19069 .19888 .20740 .16631 .17368 .18138 .18941 .19777 .15795 .16514 .17267 .18053 .18873 .15013 .15715 .16450 .17220 .18023 45 46 47 48 49 .28987 .29976 .30987 .32023 .33082 .27555 .28533 .29535 .30563 .31615 .26212 .27179 .28171 .29190 .30234 .24953 .25908 .26889 .27897 .28931 .23772 .24714 .25682 .26678 .27702 .22664 .23591 .24546 .25530 .26543 .21622 .22536 .23476 .24447 .25447 .20644 .21542 .22468 .23425 .24412 .19724 .20606 .21518 .22460 .23434 .18858 .19725 .20621 .21549 .22509 50 51 52 53 54 .34166 .35274 .36402 .37550 .38717 .32694 .33798 .34924 .36070 .37237 .31306 .32404 .33525 .34668 .35833 .29995 .31085 .32200 .33339 .34500 .28756 .29838 .30946 .32078 .33234 .27586 .28658 .29757 .30882 .32031 .26479 .27541 .28630 .29746 .30888 .25432 .26482 .27561 .28667 .29801 .24441 .25479 .26547 .27643 .28766 .23502 .24528 .25584 .26669 .27782 55 56 57 58 59 .39903 .41108 .42330 .43566 .44811 .38424 .39631 .40857 .42098 .43351 .37019 .38227 .39455 .40699 .41956 .35683 .36890 .38118 .39364 .40623 .34413 .35617 .36844 .38089 .39350 .33205 .34405 .35629 .36873 .38133 .32056 .33250 .34469 .35710 .36968 .30961 .32149 .33363 .34600 .35855 .29918 .31099 .32306 .33538 .34789 .28925 .30097 .31297 .32522 .33768 60 61 62 63 64 .46066 .47330 .48608 .49898 .51200 .44613 .45887 .47175 .48478 .49793 .43224 .44505 .45802 .47115 .48442 .41896 .43182 .44485 .45807 .47143 .40624 .41914 .43223 .44550 .45895 .39408 .40699 .42011 .43343 .44694 .38243 .39535 .40848 .42184 .43539 .37127 .38418 .39732 .41069 .42427 .36058 .37347 .38660 .39997 .41357 .35033 .36318 .37629 .38966 .40326 65 66 67 68 69 70 .52512 .53835 .55174 .56524 .57882 .59242 .51121 .52461 .53818 .55188 .56568 .57951 .49782 .51137 .52511 .53899 .55299 .56703 .48495 .49862 .51250 .52654 .54071 .55495 .47255 .48634 .50034 .51452 .52885 .54325 .46062 .47449 .48860 .50291 .51737 .53193 .44912 .46307 .47727 .49168 .50627 .52096 .43805 .45206 .46633 .48083 .49552 .51034 .42738 .44143 .45576 .47034 .48513 .50004 .41709 .43118 .44556 .46020 .47506 .49007 1999–20 I.R.B. 11 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 71 72 73 74 .60598 .61948 .63287 .64621 .59332 .60707 .62073 .63435 .58106 .59504 .60895 .62282 .56918 .58338 .59751 .61162 .55767 .57206 .58640 .60073 .54651 .56108 .57561 .59015 .53569 .55043 .56513 .57985 .52520 .54009 .55495 .56984 .51503 .53004 .54505 .56009 .50516 .52029 .53543 .55061 75 76 77 78 79 .65953 .67287 .68622 .69954 .71278 .64796 .66160 .67526 .68892 .70250 .63671 .65063 .66459 .67856 .69246 .62575 .63995 .65419 .66845 .68265 .61510 .62954 .64404 .65858 .67308 .60473 .61940 .63415 .64895 .66372 .59463 .60952 .62450 .63955 .65457 .58480 .59989 .61509 .63036 .64563 .57523 .59050 .60590 .62140 .63690 .56591 .58135 .59694 .61264 .62836 80 81 82 83 84 .72581 .73857 .75101 .76311 .77497 .71588 .72899 .74178 .75423 .76645 .70618 .71962 .73274 .74553 .75809 .69668 .71045 .72389 .73700 .74988 .68740 .70147 .71522 .72864 .74183 .67833 .69268 .70672 .72044 .73393 .66945 .68408 .69840 .71240 .72618 .66077 .67566 .69024 .70451 .71857 .65227 .66741 .68225 .69678 .71110 .64396 .65933 .67441 .68919 .70377 85 86 87 88 89 .78665 .79805 .80904 .81962 .82978 .77848 .79025 .80159 .81251 .82302 .77047 .78258 .79427 .80552 .81636 .76260 .77504 .78706 .79865 .80980 .75487 .76764 .77998 .79188 .80335 .74728 .76036 .77301 .78521 .79699 .73982 .75320 .76615 .77865 .79072 .73250 .74617 .75940 .77220 .78455 .72530 .73925 .75277 .76584 .77847 .71823 .73245 .74624 .75958 .77248 90 91 92 93 94 .83952 .84870 .85716 .86494 .87216 .83309 .84260 .85136 .85942 .86690 .82676 .83658 .84563 .85396 .86170 .82052 .83064 .83998 .84858 .85657 .81437 .82479 .83441 .84326 .85149 .80831 .81902 .82891 .83801 .84648 .80234 .81332 .82348 .83283 .84153 .79645 .80771 .81812 .82771 .83664 .79064 .80217 .81283 .82266 .83181 .78492 .79671 .80761 .81767 .82704 95 96 97 98 99 .87898 .88537 .89127 .89680 .90217 .87397 .88060 .88672 .89245 .89803 .86902 .87587 .88221 .88815 .89393 .86412 .87121 .87775 .88389 .88987 .85928 .86659 .87335 .87968 .88585 .85450 .86203 .86898 .87551 .88187 .84977 .85751 .86467 .87138 .87793 .84510 .85305 .86040 .86730 .87402 .84049 .84864 .85618 .86326 .87016 .83592 .84427 .85200 .85926 .86633 100 101 102 103 104 .90738 .91250 .91751 .92247 .92775 .90344 .90876 .91396 .91912 .92460 .89953 .90504 .91045 .91579 .92148 .89567 .90137 .90696 .91249 .91839 .89183 .89772 .90350 .90922 .91532 .88804 .89412 .90007 .90598 .91227 .88428 .89054 .89668 .90276 .90924 .88056 .88699 .89331 .89957 .90624 .87687 .88348 .88997 .89640 .90326 .87322 .88000 .88666 .89326 .90031 105 106 107 108 109 .93290 .93948 .94739 .95950 .97985 .92996 .93680 .94504 .95767 .97893 .92704 .93415 .94271 .95585 .97801 .92415 .93151 .94039 .95404 .97710 .92127 .92889 .93808 .95224 .97619 .91841 .92628 .93579 .95045 .97529 .91558 .92370 .93351 .94867 .97438 .91276 .92113 .93124 .94689 .97348 .90997 .91857 .92899 .94512 .97259 .90719 .91604 .92675 .94336 .97170 May 17, 1999 12 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0% 0 1 2 3 4 .03034 .02279 .02347 .02444 .02558 .02857 .02094 .02155 .02243 .02349 .02700 .01929 .01983 .02065 .02163 .02559 .01782 .01829 .01905 .01996 .02433 .01650 .01692 .01761 .01846 .02321 .01533 .01569 .01632 .01712 .02220 .01427 .01458 .01516 .01590 .02129 .01331 .01358 .01412 .01481 .02047 .01246 .01268 .01317 .01382 .01973 .01168 .01187 .01232 .01292 5 6 7 8 9 .02686 .02825 .02976 .03137 .03311 .02469 .02600 .02742 .02894 .03059 .02275 .02398 .02532 .02675 .02832 .02101 .02217 .02343 .02479 .02627 .01945 .02053 .02172 .02301 .02442 .01804 .01906 .02019 .02140 .02274 .01677 .01773 .01880 .01995 .02122 .01562 .01653 .01754 .01864 .01985 .01458 .01544 .01640 .01744 .01859 .01364 .01445 .01536 .01635 .01745 10 11 12 13 14 .03499 .03700 .03913 .04135 .04359 .03237 .03428 .03632 .03843 .04057 .03001 .03183 .03377 .03579 .03783 .02788 .02961 .03146 .03339 .03534 .02595 .02760 .02937 .03122 .03308 .02420 .02578 .02748 .02924 .03102 .02262 .02413 .02575 .02744 .02915 .02118 .02262 .02418 .02580 .02744 .01987 .02125 .02275 .02431 .02587 .01867 .02000 .02144 .02294 .02444 15 16 17 18 19 .04584 .04806 .05029 .05253 .05484 .04270 .04482 .04692 .04905 .05124 .03986 .04187 .04387 .04588 .04796 .03728 .03919 .04108 .04299 .04496 .03493 .03674 .03855 .04036 .04222 .03279 .03452 .03623 .03795 .03972 .03083 .03248 .03411 .03574 .03742 .02905 .03063 .03218 .03373 .03532 .02742 .02892 .03040 .03187 .03339 .02593 .02736 .02877 .03017 .03161 20 21 22 23 24 .05726 .05980 .06246 .06524 .06819 .05354 .05595 .05847 .06112 .06392 .05013 .05242 .05482 .05734 .06001 .04702 .04920 .05147 .05387 .05642 .04418 .04625 .04841 .05069 .05312 .04158 .04354 .04559 .04777 .05008 .03919 .04105 .04301 .04508 .04728 .03700 .03877 .04063 .04260 .04470 .03498 .03667 .03844 .04032 .04232 .03313 .03473 .03642 .03821 .04012 25 26 27 28 29 .07131 .07460 .07810 .08179 .08566 .06690 .07005 .07340 .07693 .08065 .06285 .06586 .06907 .07246 .07603 .05913 .06200 .06508 .06833 .07176 .05570 .05845 .06140 .06451 .06780 .05255 .05518 .05800 .06098 .06414 .04964 .05215 .05485 .05772 .06075 .04695 .04936 .05195 .05469 .05761 .04447 .04677 .04925 .05189 .05469 .04218 .04438 .04676 .04929 .05198 30 31 32 33 34 .08973 .09398 .09843 .10310 .10799 .08456 .08865 .09294 .09745 .10217 .07978 .08372 .08785 .09220 .09676 .07536 .07915 .08313 .08732 .09173 .07127 .07491 .07875 .08279 .08705 .06748 .07098 .07468 .07858 .08269 .06396 .06733 .07089 .07466 .07862 .06069 .06394 .06737 .07100 .07483 .05766 .06078 .06409 .06759 .07129 .05483 .05785 .06103 .06441 .06798 35 36 37 38 39 .11314 .11852 .12416 .13009 .13629 .10715 .11236 .11783 .12359 .12962 .10157 .10662 .11193 .11751 .12338 .09638 .10127 .10641 .11183 .11753 .09155 .09628 .10126 .10652 .11206 .08704 .09162 .09645 .10155 .10693 .08283 .08726 .09194 .09689 .10212 .07890 .08319 .08772 .09253 .09761 .07522 .07938 .08377 .08843 .09337 .07179 .07581 .08006 .08459 .08938 1999–20 I.R.B. 13 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0% 40 41 42 43 44 .14281 .14966 .15685 .16437 .17224 .13597 .14264 .14966 .15702 .16472 .12955 .13606 .14291 .15010 .15764 .12355 .12989 .13657 .14360 .15098 .11791 .12409 .13061 .13747 .14469 .11262 .11864 .12500 .13171 .13876 .10766 .11352 .11972 .12627 .13317 .10299 .10870 .11475 .12115 .12789 .09860 .10417 .11006 .11631 .12290 .09447 .09989 .10564 .11174 .11819 45 46 47 48 49 .18042 .18893 .19775 .20688 .21633 .17274 .18110 .18975 .19873 .20804 .16550 .17370 .18220 .19102 .20018 .15867 .16671 .17505 .18373 .19274 .15223 .16011 .16830 .17682 .18568 .14615 .15387 .16190 .17027 .17898 .14040 .14796 .15584 .16406 .17262 .13496 .14238 .15010 .15817 .16658 .12982 .13708 .14466 .15258 .16084 .12496 .13207 .13950 .14727 .15539 50 51 52 53 54 .22612 .23625 .24669 .25742 .26845 .21769 .22769 .23799 .24861 .25952 .20969 .21955 .22973 .24022 .25101 .20210 .21182 .22186 .23222 .24290 .19490 .20448 .21438 .22461 .23516 .18805 .19749 .20726 .21735 .22777 .18155 .19084 .20047 .21043 .22072 .17536 .18452 .19400 .20383 .21399 .16948 .17849 .18784 .19753 .20756 .16388 .17275 .18196 .19151 .20140 55 56 57 58 59 .27978 .29140 .30333 .31551 .32790 .27074 .28227 .29411 .30621 .31854 .26212 .27355 .28529 .29731 .30956 .25389 .26522 .27686 .28878 .30095 .24604 .25725 .26879 .28061 .29269 .23853 .24963 .26106 .27278 .28477 .23136 .24233 .25365 .26528 .27716 .22450 .23535 .24656 .25807 .26986 .21793 .22867 .23976 .25116 .26284 .21166 .22227 .23324 .24453 .25610 60 61 62 63 64 .34050 .35331 .36639 .37974 .39334 .33107 .34384 .35688 .37020 .38378 .32202 .33473 .34772 .36101 .37456 .31334 .32598 .33892 .35216 .36568 .30500 .31757 .33044 .34363 .35711 .29699 .30948 .32229 .33542 .34884 .28929 .30170 .31443 .32750 .34087 .28190 .29422 .30687 .31986 .33317 .27478 .28701 .29958 .31250 .32574 .26794 .28007 .29255 .30539 .31857 65 66 67 68 69 70 .40718 .42128 .43569 .45038 .46531 .48040 .39761 .41172 .42616 .44089 .45587 .47103 .38838 .40249 .41694 .43170 .44672 .46194 .37947 .39357 .40803 .42281 .43786 .45312 .37087 .38496 .39941 .41419 .42927 .44456 .36257 .37663 .39107 .40585 .42094 .43626 .35455 .36858 .38299 .39777 .41286 .42820 .34681 .36079 .37518 .38994 .40503 .42038 .33932 .35326 .36761 .38235 .39743 .41278 .33208 .34597 .36028 .37499 .39006 .40540 71 72 73 74 .49558 .51082 .52607 .54139 .48629 .50162 .51697 .53241 .47727 .49268 .50813 .52367 .46851 .48399 .49952 .51515 .46000 .47554 .49114 .50686 .45174 .46733 .48299 .49879 .44371 .45934 .47506 .49092 .43591 .45157 .46733 .48325 .42832 .44401 .45981 .47578 .42095 .43666 .45249 .46849 75 76 77 78 79 .55683 .57243 .58819 .60408 .62001 .54798 .56373 .57965 .59572 .61184 .53936 .55524 .57132 .58755 .60385 .53095 .54696 .56318 .57957 .59604 .52276 .53888 .55523 .57177 .58840 .51477 .53100 .54747 .56414 .58092 .50698 .52330 .53988 .55668 .57360 .49938 .51579 .53247 .54939 .56644 .49197 .50846 .52523 .54225 .55943 .48474 .50130 .51815 .53527 .55256 May 17, 1999 14 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 6.2% 6.4% 6.6% 6.8% 7.0% 7.2% 7.4% 7.6% 7.8% 8.0% 80 81 82 83 84 .63582 .65142 .66673 .68175 .69657 .62786 .64367 .65920 .67444 .68950 .62007 .63608 .65182 .66728 .68256 .61244 .62864 .64458 .66024 .67574 .60497 .62135 .63748 .65334 .66904 .59765 .61421 .63052 .64656 .66246 .59048 .60721 .62368 .63991 .65599 .58347 .60034 .61698 .63338 .64964 .57659 .59361 .61041 .62696 .64340 .56985 .58701 .60395 .62066 .63727 85 86 87 88 89 .71128 .72576 .73981 .75342 .76658 .70446 .71919 .73349 .74735 .76076 .69775 .71272 .72726 .74137 .75503 .69116 .70636 .72114 .73548 .74938 .68467 .70010 .71511 .72968 .74381 .67830 .69394 .70917 .72396 .73832 .67204 .68789 .70333 .71833 .73290 .66587 .68193 .69757 .71279 .72757 .65982 .67606 .69190 .70732 .72231 .65386 .67029 .68632 .70194 .71712 90 91 92 93 94 .77928 .79131 .80246 .81274 .82232 .77371 .78600 .79737 .80788 .81766 .76823 .78075 .79235 .80307 .81306 .76281 .77557 .78740 .79832 .80850 .75748 .77046 .78250 .79363 .80401 .75221 .76542 .77767 .78899 .79956 .74702 .76044 .77290 .78441 .79517 .74190 .75553 .76818 .77989 .79082 .73684 .75068 .76353 .77542 .78653 .73186 .74589 .75893 .77100 .78228 95 96 97 98 99 .83141 .83996 .84787 .85530 .86255 .82695 .83569 .84378 .85138 .85880 .82254 .83147 .83973 .84750 .85508 .81818 .82729 .83573 .84366 .85140 .81387 .82316 .83176 .83985 .84776 .80961 .81907 .82784 .83609 .84415 .80539 .81503 .82396 .83236 .84057 .80122 .81103 .82012 .82867 .83703 .79710 .80707 .81632 .82502 .83353 .79302 .80315 .81255 .82140 .83005 100 101 102 103 104 .86960 .87655 .88338 .89015 .89737 .86601 .87313 .88012 .88706 .89446 .86246 .86974 .87689 .88399 .89157 .85894 .86638 .87369 .88095 .88871 .85546 .86305 .87052 .87793 .88586 .85200 .85975 .86738 .87494 .88304 .84858 .85648 .86426 .87197 .88024 .84519 .85324 .86116 .86903 .87745 .84183 .85003 .85809 .86611 .87469 .83849 .84684 .85505 .86321 .87195 105 106 107 108 109 .90443 .91351 .92452 .94161 .97081 .90170 .91101 .92230 .93987 .96992 .89898 .90852 .92010 .93814 .96904 .89628 .90605 .91791 .93641 .96816 .89360 .90359 .91573 .93469 .96729 .89094 .90115 .91356 .93298 .96642 .88830 .89873 .91141 .93128 .96555 .88568 .89632 .90927 .92958 .96468 .88307 .89392 .90714 .92790 .96382 .88049 .89154 .90502 .92622 .96296 1999–20 I.R.B. 15 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0% 0 1 2 3 4 .01906 .01098 .01113 .01155 .01211 .01845 .01034 .01046 .01084 .01137 .01790 .00977 .00986 .01020 .01069 .01740 .00924 .00930 .00962 .01008 .01694 .00876 .00880 .00909 .00952 .01652 .00833 .00834 .00860 .00900 .01613 .00793 .00791 .00816 .00853 .01578 .00756 .00753 .00775 .00810 .01546 .00722 .00717 .00737 .00770 .01516 .00691 .00684 .00702 .00733 5 6 7 8 9 .01279 .01356 .01442 .01536 .01641 .01201 .01274 .01356 .01446 .01546 .01130 .01199 .01277 .01363 .01460 .01065 .01131 .01205 .01287 .01380 .01006 .01068 .01140 .01218 .01307 .00952 .01011 .01079 .01154 .01240 .00902 .00959 .01023 .01096 .01178 .00856 .00910 .00972 .01041 .01120 .00814 .00865 .00925 .00991 .01068 .00775 .00824 .00881 .00945 .01019 10 11 12 13 14 .01758 .01886 .02024 .02168 .02313 .01659 .01781 .01915 .02054 .02193 .01567 .01686 .01814 .01948 .02083 .01484 .01598 .01721 .01851 .01981 .01407 .01517 .01636 .01762 .01887 .01336 .01442 .01558 .01679 .01801 .01270 .01373 .01485 .01603 .01721 .01210 .01310 .01419 .01533 .01646 .01154 .01251 .01357 .01467 .01578 .01103 .01196 .01299 .01407 .01514 15 16 17 18 19 .02456 .02593 .02728 .02861 .02998 .02330 .02462 .02590 .02717 .02847 .02214 .02340 .02463 .02584 .02708 .02107 .02229 .02346 .02462 .02580 .02009 .02126 .02238 .02348 .02461 .01918 .02030 .02138 .02243 .02351 .01834 .01942 .02046 .02146 .02249 .01756 .01860 .01960 .02056 .02154 .01684 .01785 .01880 .01972 .02066 .01617 .01714 .01806 .01894 .01984 20 21 22 23 24 .03142 .03295 .03455 .03626 .03809 .02984 .03130 .03283 .03446 .03620 .02839 .02978 .03124 .03279 .03446 .02704 .02837 .02976 .03124 .03283 .02580 .02706 .02839 .02981 .03133 .02465 .02585 .02712 .02847 .02993 .02357 .02473 .02594 .02723 .02863 .02258 .02368 .02484 .02608 .02741 .02165 .02271 .02382 .02500 .02628 .02079 .02180 .02286 .02400 .02522 25 26 27 28 29 .04005 .04216 .04444 .04687 .04946 .03808 .04010 .04229 .04463 .04712 .03625 .03819 .04029 .04254 .04493 .03456 .03641 .03843 .04059 .04289 .03298 .03476 .03670 .03877 .04099 .03151 .03322 .03508 .03708 .03922 .03014 .03178 .03357 .03550 .03756 .02887 .03044 .03217 .03402 .03600 .02768 .02919 .03085 .03263 .03455 .02656 .02802 .02962 .03133 .03318 30 31 32 33 34 .05221 .05511 .05818 .06144 .06489 .04976 .05255 .05551 .05866 .06200 .04748 .05017 .05302 .05606 .05928 .04534 .04794 .05069 .05363 .05674 .04335 .04585 .04851 .05135 .05436 .04149 .04390 .04647 .04921 .05212 .03975 .04208 .04455 .04720 .05002 .03812 .04037 .04276 .04532 .04805 .03659 .03876 .04107 .04355 .04619 .03515 .03725 .03948 .04188 .04444 35 36 37 38 39 .06857 .07246 .07659 .08098 .08563 .06555 .06932 .07332 .07758 .08210 .06273 .06638 .07025 .07439 .07878 .06007 .06361 .06737 .07138 .07565 .05758 .06101 .06466 .06855 .07270 .05524 .05856 .06210 .06588 .06992 .05304 .05626 .05969 .06336 .06729 .05097 .05409 .05742 .06099 .06480 .04902 .05205 .05528 .05874 .06245 .04718 .05012 .05325 .05662 .06023 May 17, 1999 16 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0% 40 41 42 43 44 .09059 .09586 .10147 .10742 .11373 .08692 .09206 .09753 .10334 .10950 .08347 .08848 .09381 .09948 .10551 .08021 .08509 .09029 .09583 .10172 .07714 .08189 .08696 .09237 .09813 .07423 .07886 .08381 .08909 .09472 .07149 .07600 .08083 .08598 .09148 .06889 .07329 .07800 .08304 .08841 .06643 .07072 .07531 .08024 .08549 .06411 .06828 .07277 .07758 .08272 45 46 47 48 49 .12035 .12732 .13460 .14223 .15020 .11599 .12281 .12995 .13743 .14526 .11185 .11853 .12553 .13287 .14056 .10792 .11447 .12133 .12853 .13608 .10420 .11061 .11733 .12439 .13181 .10066 .10694 .11353 .12046 .12774 .09730 .10345 .10991 .11671 .12385 .09410 .10013 .10646 .11313 .12015 .09106 .09696 .10317 .10972 .11661 .08817 .09395 .10004 .10646 .11322 50 51 52 53 54 .15855 .16727 .17634 .18576 .19552 .15347 .16205 .17098 .18027 .18990 .14862 .15707 .16587 .17501 .18451 .14401 .15232 .16097 .16999 .17935 .13960 .14777 .15630 .16518 .17441 .13540 .14344 .15183 .16057 .16968 .13138 .13929 .14755 .15616 .16514 .12754 .13532 .14345 .15194 .16078 .12388 .13153 .13953 .14789 .15661 .12037 .12789 .13577 .14400 .15260 55 56 57 58 59 .20564 .21613 .22698 .23816 .24962 .19989 .21025 .22098 .23204 .24339 .19437 .20461 .21522 .22616 .23740 .18908 .19919 .20968 .22051 .23163 .18402 .19400 .20436 .21507 .22608 .17915 .18901 .19925 .20984 .22073 .17449 .18422 .19434 .20481 .21558 .17001 .17962 .18961 .19996 .21062 .16571 .17519 .18507 .19530 .20584 .16157 .17093 .18069 .19080 .20123 60 61 62 63 64 .26136 .27339 .28578 .29854 .31164 .25502 .26695 .27925 .29192 .30494 .24892 .26075 .27295 .28553 .29846 .24304 .25477 .26687 .27935 .29221 .23738 .24900 .26100 .27339 .28615 .23192 .24343 .25533 .26762 .28030 .22666 .23806 .24985 .26205 .27463 .22158 .23288 .24456 .25666 .26915 .21669 .22787 .23945 .25145 .26384 .21196 .22304 .23451 .24641 .25870 65 66 67 68 69 70 .32508 .33891 .35318 .36785 .38290 .39823 .31831 .33208 .34630 .36093 .37595 .39127 .31177 .32547 .33963 .35422 .36920 .38450 .30543 .31906 .33316 .34770 .36265 .37791 .29930 .31285 .32689 .34138 .35628 .37151 .29336 .30684 .32081 .33524 .35009 .36529 .28761 .30101 .31491 .32928 .34408 .35924 .28203 .29536 .30918 .32349 .33824 .35335 .27663 .28987 .30363 .31787 .33256 .34762 .27140 .28456 .29823 .31240 .32703 .34204 71 72 73 74 .41378 .42950 .44535 .46139 .40681 .42253 .43840 .45446 .40003 .41575 .43162 .44771 .39343 .40914 .42502 .44112 .38701 .40271 .41858 .43469 .38076 .39644 .41231 .42842 .37467 .39034 .40619 .42230 .36875 .38438 .40022 .41632 .36298 .37858 .39440 .41049 .35736 .37293 .38872 .40479 75 76 77 78 79 .47769 .49430 .51123 .52845 .54584 .47080 .48747 .50447 .52177 .53926 .46408 .48079 .49786 .51523 .53282 .45752 .47427 .49139 .50884 .52650 .45111 .46790 .48506 .50257 .52032 .44485 .46167 .47888 .49645 .51426 .43874 .45558 .47282 .49044 .50833 .43277 .44963 .46690 .48457 .50251 .42693 .44380 .46111 .47881 .49681 .42123 .43811 .45543 .47317 .49122 1999–20 I.R.B. 17 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 8.2% 8.4% 8.6% 8.8% 9.0% 9.2% 9.4% 9.6% 9.8% 10.0% 80 81 82 83 84 .56325 .58054 .59762 .61448 .63124 .55678 .57419 .59140 .60840 .62531 .55044 .56797 .58530 .60243 .61949 .54423 .56186 .57931 .59657 .61376 .53813 .55587 .57343 .59081 .60813 .53216 .54999 .56766 .58515 .60259 .52630 .54422 .56198 .57958 .59715 .52056 .53856 .55641 .57411 .59179 .51492 .53300 .55094 .56874 .58652 .50939 .52754 .54557 .56346 .58134 85 86 87 88 89 .64800 .66461 .68083 .69663 .71201 .64224 .65902 .67541 .69140 .70696 .63657 .65351 .67008 .68624 .70199 .63099 .64810 .66483 .68116 .69708 .62550 .64276 .65965 .67615 .69224 .62010 .63751 .65455 .67121 .68747 .61478 .63233 .64953 .66634 .68276 .60955 .62724 .64458 .66154 .67811 .60441 .62222 .63970 .65680 .67353 .59934 .61728 .63489 .65213 .66900 90 91 92 93 94 .72694 .74117 .75439 .76664 .77809 .72209 .73650 .74991 .76233 .77394 .71730 .73190 .74548 .75806 .76983 .71257 .72735 .74110 .75385 .76578 .70791 .72286 .73678 .74969 .76177 .70330 .71842 .73251 .74557 .75780 .69876 .71404 .72829 .74150 .75388 .69427 .70972 .72412 .73748 .75000 .68984 .70545 .72000 .73350 .74616 .68547 .70123 .71593 .72957 .74237 95 96 97 98 99 .78899 .79928 .80883 .81781 .82661 .78500 .79544 .80514 .81427 .82320 .78106 .79165 .80149 .81075 .81982 .77715 .78790 .79787 .80727 .81648 .77329 .78418 .79430 .80382 .81316 .76947 .78050 .79075 .80041 .80988 .76569 .77686 .78725 .79703 .80662 .76195 .77326 .78377 .79368 .80340 .75826 .76970 .78033 .79036 .80020 .75460 .76617 .77693 .78708 .79704 100 101 102 103 104 .83519 .84368 .85203 .86034 .86923 .83192 .84055 .84904 .85748 .86653 .82868 .83744 .84607 .85465 .86385 .82547 .83437 .84313 .85184 .86119 .82228 .83131 .84021 .84906 .85855 .81913 .82829 .83731 .84629 .85593 .81600 .82529 .83444 .84355 .85333 .81290 .82231 .83159 .84082 .85074 .80982 .81936 .82876 .83812 .84818 .80678 .81643 .82596 .83544 .84563 105 106 107 108 109 .87792 .88918 .90291 .92455 .96211 .87537 .88683 .90082 .92288 .96125 .87283 .88450 .89873 .92123 .96041 .87032 .88218 .89666 .91958 .95956 .86782 .87987 .89460 .91794 .95872 .86534 .87758 .89255 .91630 .95788 .86287 .87530 .89051 .91468 .95704 .86042 .87304 .88849 .91306 .95620 .85799 .87079 .88647 .91145 .95537 .85557 .86855 .88447 .90984 .95455 May 17, 1999 18 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0% 0 1 2 3 4 .01488 .00662 .00654 .00670 .00699 .01463 .00636 .00626 .00641 .00668 .01439 .00612 .00600 .00613 .00639 .01417 .00589 .00576 .00588 .00612 .01396 .00568 .00554 .00564 .00587 .01377 .00548 .00533 .00542 .00563 .01359 .00530 .00514 .00522 .00542 .01343 .00513 .00496 .00502 .00521 .01327 .00497 .00479 .00484 .00502 .01312 .00482 .00463 .00468 .00484 5 6 7 8 9 .00739 .00786 .00841 .00902 .00973 .00706 .00751 .00803 .00863 .00931 .00675 .00718 .00769 .00826 .00892 .00646 .00687 .00736 .00791 .00856 .00620 .00659 .00706 .00759 .00822 .00595 .00633 .00678 .00730 .00790 .00571 .00608 .00652 .00702 .00760 .00550 .00585 .00627 .00675 .00733 .00529 .00563 .00604 .00651 .00706 .00510 .00543 .00582 .00628 .00682 10 11 12 13 14 .01055 .01146 .01246 .01351 .01455 .01010 .01099 .01196 .01298 .01400 .00969 .01055 .01150 .01249 .01348 .00930 .01014 .01106 .01204 .01300 .00894 .00976 .01066 .01161 .01255 .00861 .00940 .01028 .01121 .01213 .00829 .00907 .00993 .01084 .01173 .00799 .00875 .00960 .01049 .01136 .00772 .00846 .00928 .01016 .01102 .00746 .00818 .00899 .00985 .01069 15 16 17 18 19 .01555 .01648 .01737 .01822 .01908 .01497 .01587 .01673 .01754 .01837 .01443 .01530 .01612 .01691 .01770 .01392 .01477 .01556 .01632 .01708 .01345 .01427 .01504 .01576 .01650 .01300 .01380 .01455 .01525 .01595 .01259 .01336 .01408 .01476 .01544 .01220 .01295 .01365 .01430 .01495 .01183 .01257 .01324 .01387 .01450 .01148 .01220 .01286 .01347 .01407 20 21 22 23 24 .01999 .02096 .02197 .02306 .02424 .01924 .02017 .02114 .02218 .02331 .01854 .01943 .02036 .02136 .02245 .01788 .01874 .01963 .02059 .02163 .01726 .01809 .01895 .01987 .02087 .01669 .01748 .01830 .01919 .02016 .01615 .01691 .01770 .01855 .01948 .01564 .01637 .01713 .01795 .01885 .01516 .01586 .01660 .01739 .01825 .01471 .01539 .01610 .01686 .01769 25 26 27 28 29 .02552 .02692 .02846 .03012 .03190 .02455 .02589 .02738 .02898 .03070 .02364 .02493 .02636 .02791 .02957 .02278 .02403 .02541 .02690 .02851 .02197 .02318 .02451 .02595 .02751 .02122 .02238 .02367 .02506 .02656 .02051 .02162 .02287 .02422 .02567 .01984 .02091 .02212 .02342 .02483 .01920 .02025 .02141 .02267 .02404 .01861 .01961 .02074 .02196 .02329 30 31 32 33 34 .03381 .03583 .03799 .04031 .04279 .03254 .03450 .03659 .03883 .04123 .03135 .03324 .03527 .03744 .03976 .03023 .03206 .03402 .03612 .03838 .02917 .03094 .03284 .03488 .03707 .02817 .02989 .03173 .03371 .03583 .02723 .02890 .03068 .03260 .03465 .02634 .02796 .02968 .03155 .03354 .02551 .02707 .02874 .03055 .03249 .02471 .02623 .02785 .02961 .03149 35 36 37 38 39 .04545 .04830 .05134 .05462 .05812 .04382 .04658 .04953 .05272 .05613 .04227 .04495 .04782 .05092 .05424 .04081 .04341 .04620 .04921 .05245 .03943 .04196 .04467 .04760 .05075 .03812 .04058 .04321 .04606 .04913 .03688 .03927 .04183 .04461 .04760 .03571 .03803 .04052 .04322 .04614 .03459 .03685 .03928 .04191 .04475 .03354 .03573 .03809 .04066 .04343 1999–20 I.R.B. 19 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0% 40 41 42 43 44 .06190 .06597 .07035 .07505 .08008 .05981 .06378 .06806 .07265 .07757 .05782 .06170 .06587 .07036 .07518 .05594 .05972 .06380 .06818 .07290 .05415 .05784 .06182 .06611 .07072 .05245 .05605 .05994 .06414 .06865 .05083 .05435 .05815 .06225 .06667 .04929 .05272 .05644 .06045 .06478 .04783 .05118 .05481 .05874 .06298 .04643 .04970 .05326 .05710 .06125 45 46 47 48 49 .08542 .09108 .09705 .10335 .10999 .08279 .08834 .09419 .10038 .10690 .08029 .08573 .09147 .09754 .10394 .07791 .08324 .08886 .09482 .10111 .07563 .08085 .08637 .09222 .09840 .07346 .07858 .08399 .08973 .09581 .07138 .07640 .08172 .08735 .09332 .06940 .07432 .07954 .08507 .09093 .06750 .07233 .07745 .08288 .08864 .06569 .07043 .07545 .08078 .08644 50 51 52 53 54 .11701 .12441 .13217 .14028 .14875 .11380 .12108 .12871 .13670 .14505 .11073 .11789 .12540 .13327 .14150 .10778 .11482 .12222 .12997 .13808 .10496 .11189 .11916 .12680 .13480 .10225 .10907 .11623 .12375 .13163 .09965 .10636 .11341 .12082 .12859 .09716 .10376 .11071 .11801 .12566 .09477 .10126 .10810 .11529 .12284 .09247 .09886 .10560 .11268 .12012 55 56 57 58 59 .15760 .16684 .17648 .18647 .19678 .15378 .16290 .17242 .18229 .19249 .15011 .15911 .16851 .17827 .18835 .14657 .15546 .16474 .17438 .18435 .14317 .15194 .16111 .17064 .18049 .13989 .14855 .15760 .16702 .17676 .13674 .14528 .15422 .16353 .17316 .13370 .14213 .15096 .16015 .16968 .13077 .13909 .14781 .15689 .16631 .12794 .13615 .14477 .15374 .16305 60 61 62 63 64 .20740 .21837 .22973 .24152 .25372 .20300 .21385 .22511 .23680 .24890 .19875 .20949 .22064 .23222 .24422 .19464 .20527 .21631 .22779 .23969 .19066 .20119 .21212 .22350 .23529 .18682 .19724 .20807 .21934 .23103 .18311 .19341 .20414 .21530 .22690 .17952 .18971 .20033 .21139 .22289 .17604 .18613 .19664 .20760 .21899 .17268 .18266 .19306 .20392 .21521 65 66 67 68 69 70 .26633 .27940 .29299 .30709 .32166 .33661 .26141 .27439 .28790 .30193 .31643 .33133 .25664 .26953 .28296 .29691 .31134 .32618 .25201 .26481 .27815 .29202 .30639 .32116 .24752 .26023 .27348 .28728 .30157 .31628 .24316 .25577 .26894 .28265 .29687 .31152 .23893 .25145 .26453 .27816 .29230 .30688 .23482 .24724 .26024 .27378 .28785 .30235 .23083 .24316 .25606 .26952 .28351 .29794 .22695 .23918 .25200 .26537 .27928 .29364 71 72 73 74 .35188 .36742 .38317 .39923 .34654 .36204 .37776 .39380 .34134 .35679 .37248 .38849 .33627 .35168 .36733 .38330 .33133 .34668 .36229 .37823 .32651 .34181 .35738 .37328 .32181 .33706 .35257 .36844 .31722 .33241 .34788 .36370 .31275 .32788 .34330 .35908 .30838 .32345 .33882 .35455 75 76 77 78 79 .41566 .43254 .44988 .46765 .48574 .41021 .42709 .44444 .46224 .48037 .40489 .42176 .43912 .45694 .47510 .39968 .41655 .43391 .45174 .46993 .39459 .41144 .42880 .44665 .46487 .38961 .40645 .42380 .44166 .45990 .38474 .40156 .41891 .43677 .45502 .37997 .39677 .41411 .43197 .45024 .37531 .39208 .40940 .42726 .44554 .37074 .38749 .40479 .42265 .44094 May 17, 1999 20 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 10.2% 10.4% 10.6% 10.8% 11.0% 11.2% 11.4% 11.6% 11.8% 12.0% 80 81 82 83 84 .50397 .52219 .54029 .55826 .57624 .49865 .51693 .53510 .55315 .57123 .49343 .51176 .53000 .54813 .56629 .48830 .50669 .52499 .54319 .56144 .48327 .50171 .52007 .53834 .55666 .47834 .49682 .51523 .53356 .55195 .47349 .49201 .51047 .52886 .54732 .46873 .48729 .50580 .52424 .54277 .46406 .48265 .50120 .51969 .53828 .45947 .47809 .49667 .51522 .53386 85 86 87 88 89 .59435 .61241 .63015 .64753 .66454 .58944 .60762 .62548 .64299 .66013 .58460 .60289 .62087 .63851 .65579 .57984 .59824 .61633 .63409 .65150 .57516 .59365 .61185 .62973 .64726 .57054 .58913 .60744 .62543 .64308 .56599 .58468 .60309 .62118 .63895 .56151 .58029 .59880 .61700 .63488 .55710 .57596 .59456 .61287 .63086 .55275 .57170 .59039 .60879 .62689 90 91 92 93 94 .68115 .69706 .71190 .72569 .73861 .67689 .69294 .70792 .72184 .73490 .67268 .68887 .70399 .71804 .73123 .66853 .68486 .70011 .71429 .72759 .66442 .68089 .69627 .71057 .72400 .66037 .67696 .69247 .70689 .72044 .65637 .67309 .68872 .70326 .71692 .65241 .66925 .68501 .69967 .71344 .64851 .66547 .68134 .69611 .71000 .64465 .66173 .67771 .69259 .70659 95 96 97 98 99 .75097 .76267 .77356 .78382 .79390 .74739 .75922 .77022 .78059 .79079 .74384 .75579 .76691 .77740 .78771 .74033 .75240 .76363 .77423 .78465 .73686 .74905 .76039 .77110 .78162 .73342 .74572 .75718 .76799 .77862 .73002 .74243 .75399 .76491 .77565 .72665 .73917 .75084 .76186 .77270 .72331 .73595 .74772 .75884 .76978 .72001 .73275 .74463 .75584 .76688 100 101 102 103 104 .80376 .81353 .82318 .83278 .84310 .80076 .81066 .82042 .83014 .84059 .79779 .80780 .81768 .82752 .83810 .79485 .80497 .81496 .82491 .83563 .79193 .80217 .81227 .82233 .83317 .78904 .79938 .80960 .81977 .83073 .78617 .79662 .80694 .81723 .82831 .78333 .79388 .80431 .81470 .82591 .78051 .79117 .80170 .81220 .82352 .77771 .78847 .79911 .80971 .82115 105 106 107 108 109 .85318 .86633 .88247 .90825 .95372 .85079 .86413 .88049 .90666 .95290 .84843 .86193 .87852 .90507 .95208 .84607 .85975 .87656 .90350 .95126 .84374 .85758 .87460 .90193 .95045 .84142 .85543 .87266 .90037 .94964 .83911 .85329 .87073 .89881 .94883 .83682 .85116 .86881 .89727 .94803 .83455 .84904 .86690 .89572 .94723 .83229 .84694 .86500 .89419 .94643 1999–20 I.R.B. 21 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0% 0 1 2 3 4 .01298 .00468 .00448 .00452 .00468 .01285 .00455 .00435 .00437 .00452 .01273 .00443 .00421 .00423 .00437 .01261 .00431 .00409 .00410 .00423 .01250 .00420 .00398 .00398 .00410 .01240 .00410 .00387 .00386 .00397 .01230 .00400 .00376 .00375 .00386 .01221 .00391 .00366 .00365 .00375 .01212 .00382 .00357 .00355 .00364 .01203 .00374 .00348 .00345 .00354 5 6 7 8 9 .00493 .00524 .00562 .00606 .00659 .00476 .00506 .00543 .00586 .00637 .00460 .00489 .00525 .00566 .00616 .00445 .00473 .00508 .00548 .00597 .00431 .00458 .00492 .00531 .00579 .00418 .00444 .00477 .00515 .00561 .00405 .00430 .00462 .00499 .00545 .00393 .00418 .00449 .00485 .00529 .00382 .00406 .00436 .00471 .00514 .00371 .00394 .00423 .00458 .00500 10 11 12 13 14 .00721 .00792 .00871 .00955 .01038 .00698 .00767 .00845 .00928 .01009 .00676 .00744 .00821 .00902 .00981 .00655 .00722 .00797 .00877 .00955 .00636 .00701 .00775 .00854 .00930 .00617 .00682 .00754 .00831 .00907 .00600 .00663 .00735 .00810 .00885 .00583 .00645 .00716 .00790 .00864 .00567 .00628 .00698 .00771 .00843 .00552 .00612 .00681 .00753 .00824 15 16 17 18 19 .01116 .01186 .01250 .01308 .01367 .01085 .01153 .01215 .01272 .01329 .01056 .01123 .01183 .01238 .01293 .01028 .01094 .01152 .01206 .01259 .01002 .01066 .01124 .01175 .01227 .00977 .01040 .01096 .01147 .01196 .00954 .01015 .01070 .01119 .01167 .00932 .00992 .01045 .01093 .01140 .00910 .00969 .01022 .01068 .01113 .00890 .00948 .00999 .01044 .01088 20 21 22 23 24 .01428 .01494 .01562 .01635 .01716 .01388 .01451 .01517 .01588 .01665 .01350 .01411 .01475 .01543 .01618 .01314 .01373 .01435 .01501 .01573 .01280 .01337 .01397 .01460 .01530 .01248 .01303 .01361 .01422 .01489 .01217 .01271 .01326 .01386 .01451 .01188 .01240 .01294 .01351 .01415 .01161 .01211 .01263 .01319 .01380 .01134 .01183 .01233 .01287 .01347 25 26 27 28 29 .01804 .01902 .02011 .02129 .02258 .01751 .01845 .01951 .02066 .02191 .01701 .01792 .01895 .02006 .02127 .01653 .01741 .01841 .01949 .02067 .01608 .01693 .01790 .01895 .02009 .01565 .01648 .01742 .01844 .01955 .01524 .01604 .01696 .01795 .01903 .01485 .01563 .01652 .01748 .01853 .01448 .01524 .01610 .01704 .01806 .01413 .01487 .01571 .01662 .01762 30 31 32 33 34 .02396 .02543 .02701 .02871 .03054 .02325 .02467 .02621 .02786 .02964 .02257 .02396 .02545 .02706 .02879 .02193 .02328 .02472 .02629 .02797 .02132 .02263 .02404 .02556 .02720 .02074 .02201 .02338 .02487 .02646 .02019 .02143 .02276 .02420 .02576 .01966 .02087 .02217 .02357 .02509 .01916 .02034 .02160 .02297 .02445 .01869 .01983 .02106 .02240 .02383 35 36 37 38 39 .03253 .03467 .03697 .03947 .04217 .03158 .03366 .03590 .03833 .04096 .03067 .03269 .03488 .03725 .03982 .02981 .03178 .03391 .03622 .03873 .02898 .03090 .03298 .03524 .03768 .02820 .03007 .03209 .03430 .03669 .02745 .02928 .03125 .03340 .03573 .02674 .02852 .03044 .03254 .03482 .02606 .02779 .02967 .03172 .03395 .02541 .02710 .02893 .03094 .03312 May 17, 1999 22 1999–20 I.R.B. TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0% 40 41 42 43 44 .04510 .04830 .05177 .05553 .05960 .04383 .04695 .05035 .05404 .05802 .04262 .04567 .04900 .05261 .05651 .04146 .04445 .04770 .05123 .05506 .04035 .04327 .04646 .04992 .05368 .03930 .04215 .04527 .04866 .05235 .03828 .04108 .04413 .04746 .05107 .03732 .04005 .04304 .04630 .04985 .03639 .03907 .04200 .04520 .04867 .03550 .03812 .04100 .04413 .04754 45 46 47 48 49 .06395 .06860 .07353 .07877 .08433 .06229 .06685 .07169 .07684 .08231 .06069 .06517 .06992 .07498 .08036 .05917 .06356 .06823 .07320 .07849 .05770 .06202 .06660 .07149 .07669 .05630 .06053 .06504 .06984 .07495 .05495 .05911 .06353 .06826 .07329 .05365 .05774 .06209 .06673 .07168 .05241 .05643 .06070 .06527 .07013 .05121 .05516 .05936 .06385 .06864 50 51 52 53 54 .09026 .09655 .10318 .11017 .11750 .08814 .09433 .10086 .10774 .11498 .08609 .09219 .09863 .10541 .11254 .08413 .09013 .09647 .10315 .11019 .08224 .08815 .09439 .10098 .10792 .08042 .08624 .09239 .09888 .10572 .07867 .08440 .09046 .09686 .10361 .07698 .08262 .08860 .09491 .10156 .07535 .08091 .08680 .09302 .09958 .07378 .07926 .08506 .09120 .09767 55 56 57 58 59 .12522 .13332 .14183 .15070 .15990 .12258 .13059 .13899 .14775 .15685 .12005 .12794 .13624 .14490 .15389 .11759 .12539 .13359 .14215 .15103 .11522 .12292 .13102 .13948 .14826 .11294 .12054 .12853 .13689 .14558 .11072 .11823 .12613 .13439 .14298 .10859 .11599 .12380 .13197 .14046 .10652 .11383 .12154 .12962 .13801 .10451 .11174 .11936 .12734 .13564 60 61 62 63 64 .16942 .17929 .18960 .20035 .21154 .16626 .17603 .18623 .19688 .20797 .16321 .17287 .18297 .19352 .20451 .16024 .16981 .17980 .19025 .20114 .15737 .16684 .17673 .18708 .19787 .15459 .16395 .17375 .18400 .19469 .15189 .16115 .17085 .18100 .19159 .14927 .15844 .16803 .17809 .18859 .14673 .15580 .16530 .17525 .18566 .14426 .15324 .16264 .17250 .18281 65 66 67 68 69 70 .22318 .23532 .24804 .26133 .27516 .28945 .21951 .23156 .24419 .25740 .27114 .28536 .21595 .22790 .24044 .25356 .26723 .28137 .21249 .22434 .23679 .24983 .26341 .27747 .20912 .22088 .23324 .24618 .25969 .27367 .20584 .21751 .22977 .24263 .25605 .26996 .20265 .21422 .22640 .23917 .25251 .26633 .19955 .21102 .22311 .23579 .24905 .26279 .19652 .20791 .21990 .23250 .24567 .25934 .19358 .20487 .21678 .22929 .24237 .25596 71 72 73 74 .30412 .31913 .33444 .35012 .29996 .31491 .33016 .34579 .29590 .31078 .32597 .34155 .29193 .30675 .32188 .33741 .28806 .30281 .31788 .33335 .28427 .29895 .31396 .32938 .28057 .29519 .31013 .32549 .27696 .29150 .30638 .32168 .27343 .28790 .30271 .31795 .26998 .28438 .29913 .31430 75 76 77 78 79 .36628 .38299 .40028 .41812 .43641 .36190 .37858 .39585 .41368 .43198 .35762 .37427 .39151 .40933 .42762 .35343 .37004 .38725 .40506 .42334 .34932 .36589 .38307 .40086 .41914 .34530 .36183 .37898 .39675 .41502 .34136 .35784 .37496 .39271 .41096 .33750 .35394 .37103 .38874 .40698 .33372 .35011 .36716 .38485 .40308 .33001 .34636 .36337 .38103 .39924 1999–20 I.R.B. 23 May 17, 1999 TABLE S BASED ON LIFE TABLE 90CM SINGLE LIFE REMAINDER FACTORS APPLICABLE AFTER APRIL 30, 1999 INTEREST RATE AGE 12.2% 12.4% 12.6% 12.8% 13.0% 13.2% 13.4% 13.6% 13.8% 14.0% 80 81 82 83 84 .45496 .47360 .49223 .51081 .52951 .45054 .46920 .48785 .50648 .52523 .44619 .46487 .48355 .50221 .52101 .44192 .46061 .47932 .49802 .51686 .43772 .45643 .47516 .49388 .51277 .43360 .45231 .47106 .48982 .50874 .42954 .44827 .46703 .48581 .50477 .42556 .44429 .46307 .48187 .50086 .42164 .44038 .45916 .47799 .49701 .41779 .43653 .45532 .47416 .49321 85 86 87 88 89 .54847 .56749 .58627 .60477 .62297 .54425 .56335 .58221 .60079 .61909 .54009 .55926 .57820 .59688 .61527 .53600 .55523 .57425 .59301 .61149 .53196 .55126 .57035 .58919 .60776 .52798 .54734 .56650 .58542 .60408 .52406 .54348 .56270 .58170 .60044 .52019 .53966 .55895 .57802 .59685 .51638 .53591 .55526 .57439 .59330 .51262 .53220 .55161 .57081 .58979 90 91 92 93 94 .64084 .65803 .67412 .68911 .70321 .63707 .65437 .67058 .68567 .69988 .63335 .65076 .66707 .68227 .69657 .62968 .64719 .66360 .67890 .69330 .62604 .64366 .66017 .67557 .69006 .62246 .64017 .65678 .67227 .68686 .61891 .63672 .65342 .66901 .68369 .61540 .63330 .65010 .66578 .68055 .61194 .62993 .64682 .66258 .67744 .60851 .62659 .64357 .65942 .67437 95 96 97 98 99 .71674 .72959 .74156 .75287 .76401 .71351 .72646 .73853 .74993 .76117 .71031 .72335 .73552 .74702 .75834 .70713 .72028 .73254 .74413 .75555 .70399 .71724 .72959 .74126 .75277 .70088 .71422 .72666 .73842 .75002 .69781 .71123 .72376 .73561 .74730 .69476 .70828 .72089 .73282 .74459 .69174 .70534 .71804 .73006 .74191 .68875 .70244 .71522 .72732 .73926 100 101 102 103 104 .77494 .78580 .79654 .80724 .81879 .77219 .78315 .79399 .80479 .81646 .76946 .78052 .79146 .80236 .81413 .76676 .77791 .78894 .79994 .81183 .76408 .77532 .78645 .79755 .80954 .76142 .77275 .78397 .79517 .80726 .75878 .77021 .78152 .79280 .80501 .75616 .76768 .77908 .79046 .80276 .75357 .76517 .77666 .78813 .80054 .75099 .76268 .77426 .78582 .79832 105 106 107 108 109 .83005 .84485 .86311 .89266 .94563 .82782 .84277 .86124 .89114 .94484 .82560 .84071 .85937 .88963 .94405 .82340 .83866 .85751 .88812 .94326 .82121 .83662 .85566 .88662 .94248 .81904 .83459 .85382 .88513 .94170 .81688 .83257 .85199 .88364 .94092 .81474 .83057 .85017 .88216 .94014 .81260 .82857 .84835 .88068 .93937 .81049 .82659 .84655 .87922 .93860 (f) Effective dates. This section applies after April 30, 1999. Par. 6. Immediately following §1.643(d)–2, the undesignated centerheading is revised to read as follows: Pooled Income Fund Actuarial Tables Applicable Before May 1, 1999 Par. 7. Section 1.642(c)–6A is amended by: 1. Revising the section heading. 2. Amending newly designated paragraph (e) as follows: a. Paragraph (e) heading is revised. May 17, 1999 b. Paragraph (e)(1), first sentence is revised. c. Paragraph (e)(2)(ii) is revised. d. Paragraph (e)(3) is revised. e. Paragraph (e)(4) is revised. f. Paragraph (e)(5) introductory text is revised. g. Paragraph (e)(5), the heading for Table S is revised. The revisions read as follows: §1.642(c)–6A Valuation of charitable remainder interests for which the valuation date is before May 1, 1999. 24 * * * * * (e) Present value of the remainder interest in the case of transfers to pooled income funds for which the valuation date is after April 30, 1989, and before May 1, 1999—(1) In general. In the case of transfers to pooled income funds for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a remainder interest is determined under this section. * * * (2) * * * (ii) Discount at a rate of interest, compounded annually, equal to the highest 1999–20 I.R.B. yearly rate of return of the pooled income fund for the 3 taxable years immediately preceding its taxable year in which the transfer of property to the fund is made. The provisions of §1.642(c)–6(c) apply for determining the yearly rate of return. However, where the taxable year is less than 12 months, the provisions of §1.642(c)–6T(e)(3)(ii) apply for the determining the yearly rate of return. (3) Pooled income funds in existence less than 3 taxable years. The provisions of §1.642(c)–6T(e)(4) apply for determining the highest yearly rate of return when the pooled income fund has been in existence less than three taxable years. (4) Computation of value of remainder interest. The factor that is used in determining the present value of a remainder interest that is dependent on the termination of the life of one individual is the factor from Table S in paragraph (e)(5) of this section under the appropriate yearly rate of return opposite the number that corresponds to the age of the individual upon whose life the value of the remainder interest is based. Table S in paragraph (e)(5) of this section includes factors for yearly rates of return from 4.2 to 14 percent. Many actuarial factors not contained in Table S in paragraph (e)(5) of this section are contained in Table S in Internal Revenue Service Publication 1457, “Actuarial Values, Alpha Volume,” (8–89). Publication 1457 is no longer available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. However, pertinent factors in this publication may be obtained by a written request to: CC:DOM:CORP:R (IRS Publication 1457), room 5226,Internal Revenue Service, POB 7604, Ben Franklin Station, Washington, DC 20044. For other situations, see §1.642(c)–6(b). If the yearly rate of return is a percentage that is between the yearly rates of return for which factors are provided, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the fair market value of the property on the valuation date by the appropriate remainder factor. For an example of a computation of the present value of a remainder interest requiring a linear interpolation adjustment, see §1.642(c)–6T(e)(5). 1999–20 I.R.B. TABLE S.—BASED ON LIFE TABLE 80CNSMT SINGLE LIFE REMAINDER FACTORS [Applicable After April 30, 1989, and Before May 1, 1999] value of a charitable remainder unitrust interest is dependent on the termination of a life interest , see §1.664–4T(e)(7). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. * * * * * * * * * * Par. 8. Section 1.664–4 is amended as follows: 1. Paragraph (a)(1) is revised. 2. Paragraph (d) is removed. 3. Paragraphs (e) heading, (e)(1) through (e)(5), and (e)(6) heading, introductory text , and Table U(1) are redesignated as §1.664–4A(e) heading, (e)(1) through (e)(5) and (e)(6) heading, introductory text, and Table U(1), respectively. 4. New paragraphs (d) through (e)(5) are added. 5. New paragraph heading and introductory text are added to remaining paragraph (e)(6) preceding Table D. 6. Paragraph (f) is revised. The additions and revision read as follows: (f) Effective dates. This section applies after April 30, 1989, and before May 1, 1999. Par. 9 Section 1.664–4T is added to read as follows: (5) Actuarial tables. In the case of transfers for which the valuation date is after April 30, 1989, and before May 1, 1999, the present value of a remainder interest dependent on the termination of one life in the case of a transfer to a pooled income fund is determined by use of the following tables: §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)(5) [Reserved]. For further guidance, see §1.664–4T(d) through (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 after April 30, 1999, where the present 25 §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 of lx set forth in Table 90CM contained in §20.2031–7T(d)(7) of this chapter (Estate Tax Regulations) in the case of transfers for which the valuation date is after April 30, 1999; or from Table 80CNSMT contained §20.2031–7A(e)(4) of this chapter in the case of transfer for which the valuation date is after April 30, 1989, and before May 1, 1999. See §20.2031–7A(a) through (d) of this chapter, whichever is applicable, for transfers for which the valuation date is before May 1, 1989; (a)(2) through (c) [Reserved] For further guidance, see §1,664–4(a)(2) through (c). (d) Valuation. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664– 3) for transfers for which the valuation date is after April 30, 1999, is its present value determined under paragraph (e) of this section. The fair market value of a remainder interest in a charitable remainder unitrust (as described in §1.664–3) for transfers for which the valuation date is before May 1, 1999, is its present value determined under the following sections: May 17, 1999 Valuation Dates After Before — 12-31-51 12-31-70 11-30-83 04-30-89 01-01-52 01-01-71 12-01-83 05-01-89 05-01-99 Applicable Regulations 1.664-4A(a) 1.664–4A(b) 1.664–4A(c) 1.664–4A(d) 1.664–4A(e) (e) Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is after April 30, 1999—(1) In general. Except as otherwise provided in paragraph (e)(2) of this section, in the case of transfers for which the valuation date is after April 30, 1999, the present value of a remainder interest is determined under paragraphs (e)(3) through (e)(6) of this section, provided that the amount of the payout as of any payout date during any taxable year of the trust is not larger than the amount that the trust could distribute on such date under §1.664–3(a)(1)(v) if the taxable year of the trust were to end on such date. See, however, §1.7520– 3(b) (relating to exceptions to the use of the prescribed tables under certain circumstances). (2) Transitional rules for valuation of charitable remainder unitrusts. (i) For purposes of sections 2055, 2106, or 2624, if on May 1, 1999, the decedent was mentally incompetent so that the disposition of the property could not be changed, and the decedent died after April 30, 1999, without having regained competency to dispose of the decedent’s property, or the decedent died within 90 days of the date that the decedent first regained competency after April 30, 1999, the present value of a remainder interest under this section is determined as if the valuation date with respect to the decedent’s gross estate is either before May 1, 1999, or after April 30, 1999, at the option of the decedent’s executor. (ii) For purposes of sections 170, 2055, 2106, 2522, or 2624, in the case of transfers to a charitable remainder unitrust for which the valuation date is after April 30, 1999, and before July 1, 1999, the present value of a remainder interest based on one or more measuring lives is determined under this section by use of the section 7520 interest rate for the month in which the valuation date occurs (See §§1.7520– 1(b) and 1.7520–2(a)(2)) and the appropriate actuarial tables under either para- May 17, 1999 graph (e)(7) of this section or §1.664– 4A(e)(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 (ii) of this section, where the donor or decedent’s executor is given the option to use the appropriate actuarial tables under either paragraph (e)(7) of this section or §1.664–4A(e)(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 (e.g., gift and income tax charitable deductions with respect to the same transfer must be determined based on the same tables, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on the same tables). (3) Adjusted payout rate. For transfers for which the valuation date is after April 30, 1989, the adjusted payout rate is determined by using the appropriate Table F in §1.664–4(e)(6), for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see §1.664–4(e)(6). If the interest rate is below 4.2 percent or greater than 14 percent, see §1.664–4(b). The adjusted payout rate is determined by multiplying the fixed percentage described in §1.664–3(a)(1)(i)(a) by the factor describing the payout sequence of the trust and the number of months by which the valuation date for the first full taxable year of the trust precedes the first payout date for such taxable year. If the governing instrument does not prescribe when the distribution or distributions shall be made during the taxable year of the trust, see §1.664–4(a). In the case of a trust having a payout sequence for which no figures have been provided by the appropriate table, and in the case of a trust that determines the fair market value of the trust assets by taking the average of valuations on more than one date during the taxable year, see §1.664–4(b). (4) Period is a term of years. If the period described in §1.664–3(a)(5) is a term of years, the factor that is used in determining the present value of the remainder interest for transfers for which the valuation date is after November 30, 1983, is the factor under the appropriate adjusted payout rate in Table D of §1.664–4(e)(6) corresponding to the number of years in 26 the term. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in Table D, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the appropriate valuation date) of the property placed in trust by the factor determined under this paragraph. For purposes of this section, the valuation date is, in the case of an inter vivos transfer, the date on which the property is transferred to the trust by the donor. However, 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 date of transfer falls, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. In the case of a testamentary transfer under section 2055, 2106, or 2624, the valuation date is the date of death, unless the alternate valuation date is elected under section 2032, in which event, and within the limitations set forth in section 2032 and the regulations thereunder, the valuation date is the alternate valuation date. If the decedent’s estate elects the alternate valuation date under section 2032 and also elects, under section 7520 and §1.7520–2(b), to use the interest rate component for one of the 2 months preceding the alternate valuation date, the month so elected is the valuation date for purposes of determining the interest rate and mortality tables. The application of this paragraph (e)(4) may be illustrated by the following example: Example. D transfers $100,000 to a charitable remainder unitrust on January 1. The trust instrument requires that the trust pay 8 percent of the fair market value of the trust assets as of January 1st for a term of 12 years to D in quarterly payments (March 31, June 30, September 30, and December 31). The section 7520 rate for January (the month that the transfer occurred) is 9.6 percent. Under Table F(9.6) in §1.664–4(e)(6), the appropriate adjustment factor is .944628 for quarterly payments payable at the end of each quarter. The adjusted payout rate is 7.557 (8% ⫻ .944628). Based on the remainder factors in Table D in §1.664–4(e)(6), the present value of the remainder interest is $38,950.30, computed as follows: Factor at 7.4 percent for 12 years ......... .397495 Factor at 7.6 percent for 12 years ......... .387314 Difference ............................................. .010181 1999–20 I.R.B. Interpolation adjustment: 7.557% – 7.4% 0.2% x = = x .010181 .007992 Factor at 7.4 percent for 12 years ......... .397495 Less: Interpolation adjustment ............... .007992 Interpolated factor .................................. .389503 Present value of remainder interest: ($100,000 ⫻ .389503) . . . . . . . . . . . $38,950.30 (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, 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, the age of an individual is the age of that individual at the individual’s nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, a linear interpolation must be made. The present value of the remainder interest is determined by multiplying the net fair market value (as of the valuation date as deter- mined in paragraph (e)(4) of this section) 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). The application of this paragraph (e)(5) may be illustrated by the following example: Example. A, who is 44 years and 11 months old, transfers $100,000 to a charitable remainder unitrust on January 1st. The trust instrument requires that the trust pay to A semiannually (on June 30 and December 31) 9 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 9.6 percent. Under Table F(9.6) in §1.664–4(e)(6), the appropriate adjustment factor is .933805 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 8.404 (9% ⫻ .933805). Based on the remainder factors in Table U(1) in this section, the present value of the remainder interest is $10,109.00, computed as follows: Factor at 8.4 percent at age 45 . . . . . . . . .10117 Factor at 8.6 percent at age 45 . . . . . . . . .09715 Difference. . . . . . . . . . . . . . . . . . . . . . . . .00402 Interpolation adjustment: 8.404% – 8.4% 0.2% x = = x .00402 .00008 Factor at 8.4 percent at age 45 . . . . . . . . .10117 Less: Interpolation adjustment . . . . . . . . .00008 Interpolated Factor . . . . . . . . . . . . . . . . .10109 Present value of remainder interest: ($100,000 ⫻ .10109) . . . . . . . . $10,109.00 (6) [Reserved]. (7) Actuarial Table U(1) for transfers for which the valuation date is after April 30, 1999. For transfers for which the valuation date is after April 30, 1999, the present value of a charitable remainder unitrust interest that is dependent on a term of years or the termination of a life interest is determined by using the section 7520 rate, Table U(1) in this paragraph (e)(7), and Table D and Table F(4.2) through (14.0) in §1.664–4(e)(6). See, however, §1.7520–3(b) (relating to exceptions to the use of prescribed tables under certain circumstances). Many actuarial factors not contained in the following tables are contained in Internal Revenue Service Publication 1458, “Actuarial Values, Book Beth,” (1999). A copy of this publication is available for purchase from the Superintendent of Documents, United States Government Printing Office, Washington, DC 20402. TABLE U(1) BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 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 1 2 3 4 .06177 .05543 .05716 .05920 .06143 .05580 .04925 .05081 .05268 .05475 .05061 .04388 .04528 .04699 .04889 .04609 .03919 .04045 .04201 .04376 .04215 .03509 .03622 .03765 .03926 .03871 .03151 .03252 .03382 .03530 .03570 .02838 .02927 .03046 .03182 .03307 .02563 .02642 .02750 .02876 .03075 .02321 .02391 .02490 .02605 .02872 .02109 .02170 .02260 .02366 5 6 7 8 9 .06384 .06637 .06905 .07186 .07482 .05697 .05933 .06183 .06445 .06722 .05095 .05315 .05547 .05792 .06052 .04567 .04771 .04987 .05216 .05460 .04103 .04292 .04494 .04708 .04936 .03694 .03870 .04058 .04258 .04471 .03334 .03497 .03673 .03859 .04060 .03016 .03168 .03332 .03506 .03694 .02735 .02876 .03029 .03192 .03369 .02487 .02618 .02761 .02914 .03079 10 11 12 13 14 .07793 .08120 .08461 .08812 .09168 .07015 .07323 .07645 .07976 .08313 .06327 .06617 .06920 .07234 .07552 .05718 .05991 .06277 .06574 .06874 .05179 .05435 .05706 .05985 .06269 .04700 .04942 .05197 .05461 .05729 .04274 .04502 .04744 .04993 .05247 .03896 .04111 .04339 .04576 .04815 .03559 .03762 .03978 .04202 .04428 .03259 .03450 .03655 .03867 .04081 1999–20 I.R.B. 27 May 17, 1999 BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 15 16 17 18 19 .09527 .09886 .10249 .10616 .10994 .08652 .08991 .09334 .09680 .10037 .07872 .08192 .08515 .08842 .09178 .07176 .07478 .07782 .08090 .08407 .06554 .06839 .07126 .07415 .07714 .05999 .06267 .06537 .06809 .07091 .05501 .05754 .06008 .06264 .06529 .05055 .05294 .05533 .05774 .06023 .04655 .04880 .05105 .05332 .05566 .04296 .04508 .04720 .04933 .05153 20 21 22 23 24 .11384 .11790 .12208 .12643 .13095 .10406 .10790 .11188 .11601 .12031 .09527 .09891 .10267 .10659 .11069 .08737 .09080 .09436 .09808 .10197 .08025 .08349 .08686 .09038 .09408 .07383 .07690 .08008 .08342 .08692 .06805 .07094 .07395 .07710 .08042 .06283 .06555 .06839 .07138 .07452 .05811 .06068 .06336 .06618 .06915 .05384 .05626 .05879 .06146 .06427 25 26 27 28 29 .13567 .14058 .14571 .15104 .15656 .12481 .12950 .13442 .13953 .14484 .11497 .11945 .12415 .12904 .13414 .10605 .11032 .11481 .11949 .12438 .09795 .10202 .10631 .11078 .11546 .09060 .09447 .09856 .10284 .10731 .08392 .08760 .09149 .09558 .09986 .07784 .08134 .08505 .08895 .09304 .07230 .07563 .07916 .08288 .08679 .06726 .07042 .07379 .07733 .08106 30 31 32 33 34 .16229 .16821 .17433 .18068 .18724 .15034 .15605 .16196 .16810 .17446 .13943 .14493 .15063 .15655 .16270 .12946 .13474 .14023 .14595 .15189 .12034 .12541 .13069 .13620 .14193 .11198 .11685 .12193 .12723 .13275 .10433 .10900 .11387 .11897 .12430 .09732 .10179 .10647 .11137 .11650 .09089 .09517 .09966 .10437 .10930 .08498 .08909 .09339 .09791 .10265 35 36 37 38 39 .19405 .20109 .20838 .21593 .22374 .18107 .18791 .19500 .20236 .20998 .16910 .17574 .18263 .18979 .19723 .15808 .16451 .17120 .17816 .18540 .14791 .15414 .16062 .16739 .17443 .13853 .14456 .15083 .15739 .16423 .12987 .13569 .14177 .14813 .15477 .12187 .12749 .13337 .13953 .14597 .11448 .11990 .12558 .13154 .13779 .10764 .11287 .11835 .12412 .13017 40 41 42 43 44 .23183 .24021 .24889 .25786 .26712 .21789 .22611 .23463 .24344 .25257 .20496 .21299 .22134 .23000 .23896 .19294 .20079 .20896 .21744 .22625 .18177 .18943 .19741 .20572 .21435 .17138 .17885 .18665 .19477 .20322 .16172 .16899 .17660 .18453 .19281 .15272 .15980 .16721 .17496 .18305 .14434 .15123 .15845 .16601 .17391 .13653 .14322 .15025 .15762 .16534 45 46 47 48 49 .27665 .28644 .29647 .30676 .31729 .26196 .27163 .28155 .29173 .30217 .24821 .25774 .26754 .27760 .28794 .23534 .24472 .25438 .26431 .27453 .22328 .23251 .24201 .25181 .26190 .21198 .22105 .23040 .24004 .24999 .20139 .21028 .21947 .22896 .23876 .19145 .20018 .20919 .21852 .22817 .18213 .19068 .19952 .20868 .21817 .17338 .18174 .19041 .19941 .20873 50 51 52 53 54 .32808 .33912 .35038 .36185 .37352 .31289 .32387 .33507 .34651 .35815 .29856 .30946 .32060 .33198 .34358 .28505 .29585 .30691 .31821 .32976 .27229 .28299 .29395 .30517 .31664 .26026 .27083 .28168 .29280 .30418 .24889 .25933 .27005 .28106 .29234 .23814 .24845 .25904 .26993 .28110 .22799 .23815 .24861 .25937 .27042 .21839 .22840 .23872 .24934 .26026 May 17, 1999 28 1999–20 I.R.B. BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 55 56 57 58 59 .38539 .39746 .40971 .42212 .43464 .37002 .38209 .39437 .40682 .41939 .35542 .36748 .37976 .39222 .40482 .34155 .35358 .36584 .37829 .39090 .32836 .34034 .35257 .36500 .37759 .31583 .32774 .33992 .35231 .36488 .30390 .31574 .32785 .34019 .35272 .29256 .30431 .31634 .32862 .34109 .28177 .29342 .30536 .31756 .32996 .27149 .28303 .29488 .30699 .31932 60 61 62 63 64 .44726 .45999 .47286 .48589 .49903 .43207 .44488 .45785 .47098 .48426 .41754 .43041 .44345 .45667 .47005 .40364 .41655 .42964 .44293 .45638 .39034 .40326 .41639 .42972 .44324 .37761 .39053 .40367 .41703 .43060 .36542 .37833 .39146 .40484 .41843 .35375 .36662 .37974 .39311 .40671 .34257 .35540 .36848 .38184 .39544 .33186 .34463 .35767 .37100 .38458 65 66 67 68 69 70 .51229 .52568 .53924 .55293 .56671 .58052 .49766 .51121 .52495 .53883 .55283 .56687 .48357 .49726 .51115 .52521 .53940 .55365 .47001 .48381 .49784 .51205 .52640 .54084 .45694 .47084 .48498 .49932 .51382 .52843 .44435 .45833 .47256 .48701 .50165 .51639 .43223 .44626 .46056 .47511 .48985 .50473 .42054 .43461 .44898 .46360 .47844 .49342 .40927 .42337 .43778 .45246 .46738 .48245 .39841 .41252 .42696 .44169 .45666 .47181 71 72 73 74 .59431 .60804 .62168 .63528 .58091 .59490 .60881 .62268 .56791 .58213 .59629 .61042 .55529 .56973 .58411 .59848 .54306 .55768 .57227 .58686 .53118 .54598 .56076 .57555 .51966 .53461 .54955 .56453 .50847 .52357 .53866 .55380 .49761 .51283 .52806 .54335 .48707 .50239 .51774 .53316 75 76 77 78 79 .64887 .66249 .67612 .68975 .70330 .63657 .65049 .66446 .67843 .69233 .62458 .63880 .65307 .66736 .68160 .61290 .62739 .64194 .65654 .67109 .60151 .61625 .63108 .64596 .66081 .59041 .60538 .62046 .63561 .65074 .57959 .59478 .61009 .62548 .64088 .56904 .58443 .59995 .61558 .63123 .55875 .57432 .59005 .60590 .62178 .54872 .56446 .58037 .59643 .61253 80 81 82 83 84 .71666 .72975 .74250 .75493 .76712 .70605 .71950 .73263 .74542 .75798 .69566 .70946 .72293 .73608 .74900 .68548 .69961 .71342 .72690 .74016 .67550 .68995 .70407 .71788 .73147 .66573 .68047 .69490 .70902 .72292 .65615 .67117 .68589 .70031 .71451 .64676 .66205 .67705 .69175 .70624 .63755 .65310 .66837 .68333 .69810 .62853 .64433 .65984 .67506 .69010 85 86 87 88 89 .77913 .79086 .80218 .81307 .82355 .77037 .78248 .79418 .80544 .81628 .76175 .77423 .78628 .79790 .80909 .75326 .76610 .77850 .79047 .80200 .74491 .75808 .77083 .78313 .79500 .73668 .75019 .76326 .77589 .78808 .72859 .74241 .75580 .76874 .78125 .72061 .73474 .74844 .76169 .77450 .71276 .72719 .74118 .75473 .76783 .70503 .71974 .73402 .74786 .76125 90 91 92 93 94 .83360 .84308 .85182 .85985 .86732 .82668 .83650 .84556 .85390 .86164 .81985 .83000 .83937 .84800 .85601 .81309 .82357 .83325 .84215 .85044 .80642 .81721 .82718 .83637 .84491 .79982 .81092 .82119 .83064 .83944 .79330 .80470 .81525 .82497 .83402 .78685 .79855 .80937 .81936 .82865 .78048 .79246 .80356 .81379 .82333 .77418 .78645 .79780 .80829 .81806 1999–20 I.R.B. 29 May 17, 1999 BASED ON LIFE TABLE 90CM UNITRUST SINGLE LIFE REMAINDER FACTORS APPLICABLE FOR TRANSFERS AFTER APRIL 30, 1999 ADJUSTED PAYOUT RATE AGE 4.2% 4.4% 4.6% 4.8% 5.0% 5.2% 5.4% 5.6% 5.8% 6.0% 95 96 97 98 99 .87437 .88097 .88708 .89280 .89836 .86895 .87582 .88216 .88810 .89388 .86359 .87070 .87727 .88343 .88943 .85827 .86563 .87243 .87880 .88501 .85300 .86060 .86762 .87420 .88062 .84778 .85561 .86285 .86964 .87626 .84260 .85066 .85811 .86511 .87193 .83746 .84575 .85341 .86061 .86763 .83237 .84088 .84875 .85614 .86336 .82733 .83605 .84413 .85171 .85911 100 101 102 103 104 .90375 .90905 .91424 .91939 .92485 .89948 .90500 .91040 .91575 .92144 .89525 .90097 .90658 .91214 .91805 .89103 .89696 .90278 .90854 .91467 .88685 .89298 .89900 .90496 .91131 .88269 .88902 .89524 .90139 .90796 .87856 .88509 .89150 .89785 .90463 .87445 .88118 .88778 .89432 .90131 .87037 .87729 .88408 .89081 .89800 .86632 .87342 .88040 .88732 .89471 105 106 107 108 109 [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A171a4bc5a0e6b315. Public record. Not legal advice.