26 C.F.R. § 1.664-4

Current through November 30, 2024
Section 1.664-4 - Calculation of the fair market value of the remainder interest in a charitable remainder unitrust
(a)Rules for determining present value. For purposes of sections 170, 2055, 2106, and 2522, the fair market value of a remainder interest in a charitable remainder unitrust (as described in § 1.664-3 ) is its present value determined under paragraph (d) of this section. The present value determined under this section shall be computed on the basis of-
(1) Life contingencies determined as to each life involved, from the values of lX set forth in Table 2010CM in § 20.2031-7(d)(7)(ii) of this chapter in the case of transfers for which the valuation date is on or after June 1, 2023; or from Table 2000CM contained in § 20.2031-7A(g)(4) of this chapter in the case of transfers for which the valuation date is on or after May 1, 2009, and before June 1, 2023. See § 20.2031-7A(a) through (f) of this chapter, whichever is applicable, for transfers for which the valuation date is before May 1, 2009;
(2) Interest at the section 7520 rate in the case of transfers for which the valuation date is after April 30, 1989, or 10 percent in the case of transfers to charitable remainder unitrusts made after November 30, 1983, for which the valuation date is before May 1, 1989. See § 20.2031-7A (a) through (c) of this chapter, whichever is applicable, for transfers for which the valuation date is before December 1, 1983; and
(3) The assumption that the amount described in § 1.664-3(a)(1) (i)(a) is distributed in accordance with the payout sequence described in the governing instrument. If the governing instrument does not prescribe when the distribution is made during the period for which the payment is made, for purposes of this section, the distribution is considered payable on the first day of the period for which the payment is made.
(b)Actuarial Computations by the Internal Revenue Service. The regulations in this and in related sections provide tables of actuarial factors and examples that illustrate the use of the tables in determining the value of remainder interests in property. Section 1.7520-1(c)(2) refers to government publications that provide additional tables of factors and examples of computations for more complex situations. If the computation requires the use of a factor that is not provided in this section, the Commissioner may supply the factor upon a request for a ruling. A request for a ruling must be accompanied by a recitation of the facts including the date of birth of each measuring life, and copies of the relevant documents. A request for a ruling must comply with the instructions for requesting a ruling published periodically in the Internal Revenue Bulletin (See § 601.601(d)(2)(ii) (b) of this chapter) and include payment of the required user fee. If the Commissioner furnishes the factor, a copy of the letter supplying the factor should be attached to the tax return in which the deduction is claimed. If the Commissioner does not furnish the factor, the taxpayer must furnish a factor computed in accordance with the principles set forth in this section.
(c)Statement supporting deduction required. Any claim for a deduction on any return for the value of a remainder interest in a charitable remainder unitrust must be supported by a full statement attached to the return showing the computation of the present value of such interest.
(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 on or after June 1, 2023, 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 June 1, 2023, is its present value determined under the following sections:

Table 1 to Paragraph (d)

Valuation dates Applicable
regulations
After Before
01-01-521.664-4A(a)
12-31-5101-01-711.664-4A(b)
12-31-7012-01-831.664-4A(c)
11-30-8305-01-891.664-4A(d)
04-30-8905-01-991.664-4A(e)
04-30-9905-01-091.664-4A(f)
04-30-0906-01-231.664-4A(g)

(e)Valuation of charitable remainder unitrusts having certain payout sequences for transfers for which the valuation date is on or after June 1, 2023 -
(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 on or after June 1, 2023, the present value of a remainder interest is determined under paragraphs (e)(3) through (7) of this section, provided that, in a short taxable year, the trustee must prorate the unitrust amount as provided in § 1.664-3(a)(1)(v) . See, however, § 1.7520-3(b) (relating to exceptions to the use of the prescribed tables under certain circumstances).
(2)Transitional rule for valuation of charitable remainder unitrusts. For purposes of section 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, 2019, and on or before June 1, 2023, the present value of a remainder interest based on one or more measuring lives is determined under this section by using 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 factors derived from the selected mortality table, either Table 2010CM in § 20.2031-7(d)(7)(ii) of this chapter or Table 2000CM in § 20.2031-7A(g)(4) of this chapter, at the option of the donor or the decedent's executor, as the case may be. If any previously filed income tax return is amended to use the actuarial factors based on Table 2010CM, the amended return must state at the top "AMENDED PURSUANT TO TD 9974." If any previously filed gift or estate tax return is supplemented to use the actuarial factors based on Table 2010CM, the supplemental return must state at the top "SUPPLEMENTED PURSUANT TO TD 9974." For the convenience of taxpayers, actuarial factors based on Table 2010CM appear in the current version of Table U(1), and actuarial factors based on Table 2000CM appear in the previous version of Table U(1). Both versions of Table U(1) currently are available, at no charge, electronically via the IRS website at https://www.irs.gov/retirement-plans/actuarial-tables (or a corresponding URL as may be updated from time to time). The donor or decedent's executor must consistently use the same mortality basis with respect to each interest (income, remainder, partial, etc.) in the same property, and with respect to all transfers occurring on the same valuation date. For example, gift and income tax charitable deductions with respect to the same transfer must be determined based on factors with the same mortality basis, and all assets includible in the gross estate and/or estate tax deductions claimed must be valued based on factors with the same mortality basis.
(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 paragraph (e)(6) of this section, for the section 7520 interest rate applicable to the transfer. If the interest rate is between 4.2 and 14 percent, see paragraph (e)(6) of this section. If the interest rate is below 4.2 percent or greater than 14 percent, see paragraph (b) of this section. 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 paragraph (a) of this section. 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 paragraph (b) of this section.
(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 paragraph (e)(6) of this section corresponding to the number of years in 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 paragraph (e)(6) of this section, 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 paragraph (e)(6) of this section, 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

Interpolation adjustment:

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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 -
(i)Factor. 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 on or after June 1, 2023, is the factor obtained through the use of the formula in Figure 1 to this paragraph (e)(5)(i) to at least five decimal places. The prescribed mortality table is Table 2010CM as set forth in § 20.2031-7(d)(7)(ii) of this chapter, or for periods before June 1, 2023, the appropriate table found in § 20.2031-7A of this chapter. Table 2010CM is referenced by IRS Publication 1458, Actuarial Values Version 4B. The mortality tables prescribed for periods before June 1, 2023, are referenced by prior versions of IRS Publication 1458. Alternatively, the remainder factors have been determined for the convenience of taxpayers and appear in Table U(1) under the appropriate adjusted payout rate. Table U(1) currently is available, at no charge, electronically via the IRS website at https://www.irs.gov/retirement-plans/actuarial-tables (or a corresponding URL as may be updated from time to time). Table U(1) is referenced and explained by IRS Publication 1458, Actuarial Valuations Version 4B, which will be available within a reasonable time after June 1, 2023. For purposes of the computations described in this paragraph (e)(5), the age of an individual is the age of that individual at the individual's nearest birthday. If the adjusted payout rate is an amount that is between adjusted payout rates for which factors are provided in the appropriate table, an exact method of obtaining the applicable remainder factors (such as through software using the actual adjusted payout rate and the actuarial formula in this paragraph (e)(5)) or a linear interpolation must be used, provided whichever method used is applied consistently in valuing all interests in the same property. The applicable remainder factors derived by an exact method or by interpolation must be expressed to at least five decimal places. The present value of the remainder interest is determined by multiplying the net fair market value (as of the valuation date as determined in § 1.664-4(e)(4) ) of the property placed in trust by the factor determined under this paragraph (e)(5). If the adjusted payout rate is from 0.2 to 20.0 percent, inclusive, taxpayers may see the actuarial tables referenced and explained by IRS Publication 1458, Actuarial Valuations Version 4B. Alternatively, the Commissioner may supply a factor upon a request for a ruling. See paragraph (b) of this section.

Figure 1 to Paragraph (e)(5)(i)-Formula for Determining Unitrust Remainder Factors

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(ii)Sample factors from actuarial Table U(1). For purposes of the example in paragraph (e)(5)(iii) of this section, the following factors from Table U(1) and Table F(3.2) (see paragraph (e)(6)(ii) of this section) will be used:

Table 2 to Paragraph (e)(5)(ii)

Factors From Table U(1)-Based on Table 2010CM

Adjusted payout rate
Age 4.8% 5.0% 5.2%
770.614910.603430.59223
Factors from Table F(3.2)
Factors for Computing Adjusted Payout Rates for Unitrusts
Interest at 3.2 Percent
# of Months from Annual Valuation to First PayoutAdjustment Factors for Payments at End of Period
At LeastBut Less ThanAnnualSemiannual
670.9843740.976683

(iii)Example of interpolation. After June 1, 2023, A, whose age is 76 years and 11 months, 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) 5 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 3.2 percent. Under Table F(3.2), the appropriate adjustment factor is 0.976683 for semiannual payments payable at the end of the semiannual period. The adjusted payout rate is 4.883% (5% * 0.976683). Based on interpolating between the remainder factors in Table U(1), the present value of the remainder interest is $61,015, computed as illustrated in Figure 2 to this paragraph (e)(5)(iii).

Figure 2 to Paragraph (e)(5)(iii)-Illustration of Unitrust Interpolation Method

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(6)Actuarial Table D and Tables F(0.2) through F(20.0) for transfers for which the valuation date is on or after May 1, 1989 -
(i)Remainder factors for charitable remainder unitrusts. For transfers for which the valuation date is on or after May 1, 1989, the present value of a charitable remainder unitrust interest that is dependent upon a term of years is determined by using the formula in Figure 3 to this paragraph (e)(6)(i) and calculating the final result to at least six decimal places. For the convenience of taxpayers, actuarial factors have been computed by the IRS and appear in Table D. Table D can be found on the IRS website at https://www.irs.gov/retirement-plans/actuarial-tables (or a corresponding URL as may be updated from time to time). Table D is referenced and explained in IRS Publication 1458, Actuarial Valuations Version 4B, which will be available within a reasonable time after June 1, 2023. The remainder factors from Table D also can be found in paragraph (e)(6)(iii) of this section, but only for adjusted payout rates from 4.2 to 14 percent, inclusive. For transfers for which the valuation date is on or after June 1, 2023, where the present value of a charitable remainder unitrust interest is dependent on the termination of a life interest, see paragraph (e)(5) of this section. See, however, § 1.7520-3(b) (relating to exceptions to the use of prescribed tables under certain circumstances).

Figure 3 to Paragraph (e)(6)(i)-Formula for Determining Term Certain Unitrust Remainder Factors

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(ii)Unitrust payout rate adjustment factors. For transfers for which the valuation date is on or after May 1, 1989, the unitrust payout rate adjustment factors are determined by using the formula in Figure 4 to this paragraph (e)(6)(ii) and calculating the final result to at least six decimal places. For the convenience of taxpayers, actuarial factors have been computed by the IRS, for interest rates from 0.2 to 20 percent, inclusive, and appear in Tables F(0.2) through F(20.0). Tables F(0.2) through F(20.0) can be found on the IRS website at https://www.irs.gov/retirement-plans/actuarial-tables (or a corresponding URL as may be updated from time to time). Tables F(0.2) through F(20.0) are referenced and explained in IRS Publication 1458, Actuarial Valuations Version 4B, which will be available within a reasonable time after June 1, 2023. The factors from Table F also can be found in paragraph (e)(6)(iii) of this section, but only for interest rates from 4.2 to 14 percent, inclusive.

Figure 4 to Paragraph (e)(6)(ii)-Formula for Determining Unitrust Payout Rate Adjustment Factors

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(iii)Table D and Tables F(4.2) through F(14.0). The unitrust remainder factors from Table D, for interest rates from 4.2 to 14 percent, inclusive, and the unitrust payout factors from Tables F(4.2) through F(14.0) are as follows:

Table D-Showing the Present Worth of a Remainder Interest Postponed for a Term Certain in a Charitable Remainder Unitrust

[Applicable after April 30, 1989]

YearsAdjusted payout rate
4.2%4.4%4.6%4.8%5.0%5.2%5.4%5.6%5.8%6.0%
1.958000.956000.954000.952000.950000.948000.946000.944000.942000.940000
2.917764.913936.910116.906304.902500.898704.894916.891136.887364.883600
3.879218.873723.868251.862801.857375.851971.846591.841232.835897.830584
4.842291.835279.828311.821387.814506.807669.800875.794123.787415.780749
5.806915.798527.790209.781960.773781.765670.757627.749652.741745.733904
6.773024.763392.753859.744426.735092.725855.716716.707672.698724.689870
7.740557.729802.719182.708694.698337.688111.678013.668042.658198.648478
8.709454.697691.686099.674677.663420.652329.641400.630632.620022.609569
9.679657.666993.654539.642292.630249.618408.606765.595317.584061.572995
10.651111.637645.624430.611462.598737.586251.573999.561979.550185.538615
11.623764.609589.595706.582112.568800.555766.543003.530508.518275.506298
12.597566.582767.568304.554170.540360.526866.513681.500800.488215.475920
13.572469.557125.542162.527570.513342.499469.485942.472755.459898.447365
14.548425.532611.517222.502247.487675.473496.459701.446281.433224.420523
15.525391.509177.493430.478139.463291.448875.434878.421289.408097.395292
16.503325.486773.470732.455188.440127.425533.411394.397697.384427.371574
17.482185.465355.449079.433339.418120.403405.389179.375426.362131.349280
18.461933.444879.428421.412539.397214.382428.368163.354402.341127.328323
19.442532.425304.408714.392737.377354.362542.348282.334555.321342.308624
20.423946.406591.389913.373886.358486.343690.329475.315820.302704.290106

Table D-Showing the Present Worth of a Remainder Interest Postponed for a Term Certain in a Charitable Remainder Unitrust

[Applicable after April 30, 1989]

YearsAdjusted payout rate
6.2%6.4%6.6%6.8%7.0%7.2%7.4%7.6%7.8%8.0%
1.938000.936000.934000.932000.930000.928000.926000.924000.922000.920000
2.879844.876096.872356.868624.864900.861184.857476.853776.850084.846400
3.825294.820026.814781.809558.804357.799179.794023.788889.783777.778688
4.774125.767544.761005.754508.748052.741638.735265.728933.722643.716393
5.726130.718421.710779.703201.695688.688240.680855.673535.666277.659082
6.681110.672442.663867.655383.646990.638687.630472.622346.614307.606355
7.638881.629406.620052.610817.601701.592701.583817.575048.566391.557847
8.599270.589124.579129.569282.559582.550027.540615.531344.522213.513219
9.562115.551420.540906.530571.520411.510425.500609.490962.481480.472161
10.527264.516129.505206.494492.483982.473674.463564.453649.443925.434388
11.494574.483097.471863.460866.450104.439570.429260.419171.409298.399637
12.463910.452179.440720.429527.418596.407921.397495.387314.377373.367666
13.435148.423239.411632.400320.389295.378550.368081.357879.347938.338253
14.408169.396152.384465.373098.362044.351295.340843.330680.320799.311193
15.382862.370798.359090.347727.336701.326002.315620.305548.295777.286297
16.359125.347067.335390.324082.313132.302529.292264.282326.272706.263394
17.336859.324855.313254.302044.291213.280747.270637.260870.251435.242322
18.315974.304064.292579.281505.270828.260533.250610.241044.231823.222936
19.296383.284604.273269.262363.251870.241775.232065.222724.213741.205101
20.278008.266389.255233.244522.234239.224367.214892.205797.197069.188693

Table D-Showing the Present Worth of a Remainder Interest Postponed for a Term Certain in a Charitable Remainder Unitrust

[Applicable after April 30, 1989]

YearsAdjusted payout rate
8.2%8.4%8.6%8.8%9.0%9.2%9.4%9.6%9.8%10.0%
1.918000.916000.914000.912000.910000.908000.906000.904000.902000.900000
2.842724.839056.835396.831744.828100.824464.820836.817216.813604.810000
3.773621.768575.763552.758551.753571.748613.743677.738763.733871.729000
4.710184.704015.697886.691798.685750.679741.673772.667842.661951.656100
5.651949.644878.637868.630920.624032.617205.610437.603729.597080.590490
6.598489.590708.583012.575399.567869.560422.553056.545771.538566.531441
7.549413.541089.532873.524764.516761.508863.501069.493377.485787.478297
8.504361.495637.487046.478585.470253.462048.453968.446013.438180.430467
9.463003.454004.445160.436469.427930.419539.411295.403196.395238.387420
10.425037.415867.406876.398060.389416.380942.372634.364489.356505.348678
11.390184.380934.371885.363031.354369.345895.337606.329498.321567.313811
12.358189.348936.339902.331084.322475.314073.305871.297866.290054.282430
13.328817.319625.310671.301949.293453.285178.277119.269271.261628.254187
14.301854.292777.283953.275377.267042.258942.251070.243421.235989.228768
15.277102.268184.259533.251144.243008.235119.227469.220053.212862.205891
16.254380.245656.237213.229043.221137.213488.206087.198928.192001.185302
17.233521.225021.216813.208887.201235.193847.186715.179830.173185.166772
18.214372.206119.198167.190505.183124.176013.169164.162567.156213.150095
19.196794.188805.181125.173741.166643.159820.153262.146960.140904.135085
20.180657.172946.165548.158452.151645.145117.138856.132852.127096.121577

Table D-Showing the Present Worth of a Remainder Interest Postponed for a Term Certain in a Charitable Remainder Unitrust

[Applicable after April 30, 1989]

YearsAdjusted payout rate
10.2%10.4%10.6%10.8%11.0%11.2%11.4%11.6%11.8%12.0%
1.898000.896000.894000.892000.890000.888000.886000.884000.882000.880000
2.806404.802816.799236.795664.792100.788544.784996.781456.777924.774400
3.724151.719323.714517.709732.704969.700227.695506.690807.686129.681472
4.650287.644514.638778.633081.627422.621802.616219.610673.605166.599695
5.583958.577484.571068.564708.558406.552160.545970.539835.533756.527732
6.524394.517426.510535.503720.496981.490318.483729.477214.470773.464404
7.470906.463613.456418.449318.442313.435402.428584.421858.415222.408676
8.422874.415398.408038.400792.393659.386637.379726.372922.366226.359635
9.379741.372196.364786.357506.350356.343334.336437.329663.323011.316478
10.341007.333488.326118.318896.311817.304881.298083.291422.284896.278501
11.306224.298805.291550.284455.277517.270734.264102.257617.251278.245081
12.274989.267729.260645.253734.246990.240412.233994.227734.221627.215671
13.246941.239886.233017.226331.219821.213486.207319.201317.195475.189791
14.221753.214937.208317.201887.195641.189575.183684.177964.172409.167016
15.199134.192584.186236.180083.174121.168343.162744.157320.152065.146974
16.178822.172555.166495.160634.154967.149488.144191.139071.134121.129337
17.160582.154609.148846.143286.137921.132746.127754.122939.118295.113817
18.144203.138530.133069.127811.122750.117878.113190.108678.104336.100159
19.129494.124123.118963.114007.109247.104676.100286.096071.092024.088140
20.116286.111214.106353.101694.097230.092952.088853.084927.081166.077563

Table D-Showing the Present Worth of a Remainder Interest Postponed for a Term Certain in a Charitable Remainder Unitrust

[Applicable after April 30, 1989]

YearsAdjusted payout rate
12.2%12.4%12.6%12.8%13.0%13.2%13.4%13.6%13.8%14.0%
1.878000.876000.874000.872000.870000.868000.866000.864000.862000.860000
2.770884.767376.763876.760384.756900.753424.749956.746496.743044.739600
3.676836.672221.667628.663055.658503.653972.649462.644973.640504.636056
4.594262.588866.583507.578184.572898.567648.562434.557256.552114.547008
5.521762.515847.509985.504176.498421.492718.487068.481469.475923.470427
6.458107.451882.445727.439642.433626.427679.421801.415990.410245.404567
7.402218.395848.389565.383368.377255.371226.365279.359415.353631.347928
8.353147.346763.340480.334297.328212.322224.316332.310535.304830.299218
9.310063.303764.297579.291507.285544.279690.273944.268302.262764.257327
10.272236.266098.260084.254194.248423.242771.237235.231813.226502.221302
11.239023.233102.227314.221657.216128.210725.205446.200286.195245.190319
12.209862.204197.198672.193285.188032.182910.177916.173047.168301.163675
13.184259.178877.173640.168544.163588.158766.154075.149513.145076.140760
14.161779.156696.151761.146971.142321.137809.133429.129179.125055.121054
15.142042.137266.132639.128158.123819.119618.115550.111611.107798.104106
16.124713.120245.115927.111754.107723.103828.100066.096432.092922.089531
17.109498.105334.101320.097450.093719.090123.086657.083317.080098.076997
18.096139.092273.088554.084976.081535.078227.075045.071986.069045.066217
19.084410.080831.077396.074099.070936.067901.064989.062196.059517.056947
20.074112.070808.067644.064614.061714.058938.056280.053737.051303.048974

Table F(4.2)-With Interest at 4.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.989820.984755.981389
12.996577.986432.981385.978030
23.993166.983056.978026
34.989767.979691.974679
45.986380.976338
56.983004.972996
67.979639.969666
78.976286
89.972945
910.969615
1011.966296
1112.962989
12.959693

Table F(4.4)-With Interest at 4.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.989350.984054.980533
12.996418.985806.980529.977021
23.992849.982275.977017
34.989293.978757.973517
45.985749.975251
56.982219.971758
67.978700.968277
78.975195
89.971702
910.968221
1011.964753
1112.961298
12.957854

Table F(4.6)-With Interest at 4.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.988882.983354.979680
12.996259.985183.979676.976015
23.992532.981498.976011
34.988820.977826.972360
45.985121.974168
56.981436.970524
67.977764.966894
78.974107
89.970463
910.966832
1011.963216
1112.959613
12.956023

Table F(4.8)-With Interest at 4.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.988415.982657.978830
12.996101.984561.978825.975013
23.992217.980722.975008
34.988348.976898.971206
45.984494.973089
56.980655.969294
67.976831.965515
78.973022
89.969228
910.965448
1011.961684
1112.957934
12.954198

Table F(5.0)-With Interest at 5.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.987950.981961.977982
12.995942.983941.977977.974014
23.991901.979949.974009
34.987877.975973.970057
45.983868.972013
56.979876.968069
67.975900.964141
78.971940
89.967997
910.964069
1011.960157
1112.956261
12.952381

Table F(5.2)-With Interest at 5.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.987486.981268.977137
12.995784.983323.977132.973018
23.991587.979178.973012
34.987407.975050.968911
45.983244.970940
56.979099.966847
67.974972.962771
78.970862
89.966769
910.962694
1011.958636
1112.954594
12.950570

Table F(5.4)-With Interest at 5.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.987023.980577.976295
12.995627.982707.976289.972026
23.991273.978409.972019
34.986938.974131.967769
45.982622.969871
56.978325.965629
67.974047.961407
78.969787
89.965546
910.961323
1011.957119
1112.952934
12.948767

Table F(5.6)-With Interest at 5.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.986562.979888.975455
12.995470.982092.975449.971036
23.990960.977643.971029
34.986470.973214.966630
45.982001.968805
56.977552.964416
67.973124.960047
78.968715
89.964326
910.959958
1011.955609
1112.951279
12.946970

Table F(5.8)-With Interest at 5.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.986102.979201.974618
12.995313.981480.974611.970050
23.990647.976879.970043
34.986004.972300.965496
45.981382.967743
56.976782.963206
67.972203.958692
78.967646
89.963111
910.958596
1011.954103
1112.949631
12.945180

Table F(6.0)-With Interest at 6.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.985643.978516.973784
12.995156.980869.973776.969067
23.990336.976117.969059
34.985538.971389.964365
45.980764.966684
56.976014.962001
67.971286.957341
78.966581
89.961899
910.957239
1011.952603
1112.947988
12.943396

Table F(6.2)-With Interest at 6.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.985185.977833.972952
12.995000.980259.972944.968087
23.990024.975358.968079
34.985074.970481.963238
45.980148.965628
56.975247.960799
67.970371.955995
78.965519
89.960691
910.955887
1011.951107
1112.946352
12.941620

Table F(6.4)-With Interest at 6.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.984729.977152.972122
12.994844.979652.972114.967110
23.989714.974600.967101
34.984611.969575.962115
45.979534.964576
56.974483.959602
67.969458.954654
78.964460
89.959487
910.954539
1011.949617
1112.944721
12.939850

Table F(6.6)-With Interest at 6.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.984274.976473.971295
12.994688.979046.971286.966136
23.989404.973845.966127
34.984149.968672.960995
45.978921.963527
56.973721.958408
67.968549.953317
78.963404
89.958286
910.953196
1011.948132
1112.943096
12.938086

Table F(6.8)-With Interest at 6.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.983821.975796.970471
12.994533.978442.970461.965165
23.989095.973092.965156
34.983688.967772.959879
45.978309.962481
56.972961.957219
67.967641.951985
78.962351
89.957089
910.951857
1011.946653
1112.941477
12.936330

Table F(7.0)-With Interest at 7.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.983368.975122.969649
12.994378.977839.969639.964198
23.988787.972342.964187
34.983228.966875.958766
45.977700.961439
56.972203.956033
67.966736.950658
78.961301
89.955896
910.950522
1011.945178
1112.939864
12.934579

Table F(7.2)-With Interest at 7.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.982917.974449.968830
12.994223.977239.968819.963233
23.988479.971593.963222
34.982769.965980.957658
45.977091.960400
56.971446.954851
67.965834.949335
78.960255
89.954707
910.949192
1011.943708
1112.938256
12.932836

Table F(7.4)-With Interest at 7.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.982467.973778.968013
12.994068.976640.968002.962271
23.988172.970847.962260
34.982311.965088.956552
45.976484.959364
56.970692.953673
67.964935.948017
78.959211
89.953521
910.947866
1011.942243
1112.936654
12.931099

Table F(7.6)-With Interest at 7.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.982019.973109.967199
12.993914.976042.967187.961313
23.987866.970103.961301
34.981854.964199.955451
45.975879.958331
56.969940.952499
67.964037.946703
78.958171
89.952340
910.946544
1011.940784
1112.935058
12.929368

Table F(7.8)-With Interest at 7.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.0000000.981571.972442.966387
12.993761.975447.966374.960357
23.987560.969361.960345
34.981398.963312.954353
45.975275.957302
56.969190.951329
67.963143.945393
78.957133
89.951161
910.945227
1011.939329
1112.933468
12.927644

Table F(8.0)-With Interest at 8.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.981125.971777.965578
12.993607.974853.965564.959405
23.987255.968621.959392
34980944.962429.953258
45.974673.956276
56.968442.950162
67.962250.944088
78.956099
89.949987
910.943913
1011.937879
1112.931883
12.925926

Table F(8.2)-With Interest at 8.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.980680.971114.964771
12.993454.974261.964757.958455
23.986951.967883.958441
34.980490.961547.952167
45.974072.955253
56.967695.949000
67.961361.942788
78.955068
89.948816
910.942605
1011.936434
1112.930304
12.924214

Table F(8.2)-With Interest at 8.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.980237.970453.963966
12.993301.973670.963952.957509
23.986647.967148.957494
34.980037.960669.951080
45.973472.954233
56.966951.947841
67.960473.941491
78.954039
89.947648
910.941300
1011.934994
1112.928731
12.922509

Table F(8.6)-With Interest at 8.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.979794.969794.963164
12.993148.973081.963149.956565
23.986344.966414.956550
34.979586.959793.949996
45.972874.953217
56.966209.946686
67.959589.940199
78.953014
89.946484
910.940000
1011.933559
1112.927163
12.920810

Table F(8.8)-With Interest at 8.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.979353.969136.962364
12.992996.972494.962349.955624
23.986041.965683.955609
34.979135.958919.948916
45.972278.952203
56.965468.945534
67.958706.938912
78.951992
89.945324
910.938703
1011.932129
1112.925600
12.919118

Table F(9.0)-With Interest at 9.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.978913.968481.961567
12.992844.971908.961551.954686
23.985740.964954.954670
34.978686.958049.947839
45.971683.951193
56.964730.944387
67.957826.937629
78.950972
89.944167
910.937411
1011.930703
1112.924043
12.917431

Table F(9.2)-With Interest at 9.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.978474.967827.960772
12.992693.971324.960755.953752
23.985439.964226.953734
34.978238.957180.946765
45.971089.950186
56.963993.943242
67.956949.936350
78.949956
89.943014
910.936123
1011.929283
1112.922492
12.915751

Table F(9.4)-With Interest at 9.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.978037.967176.959980
12.992541.970742.959962.952820
23.985138.963501.952802
34.977790.956315.945695
45.970497.949182
56.963258.942102
67.956074.935075
78.948942
89.941865
910.934839
1011.927867
1112.920946
12.914077

Table F(9.6)-With Interest at 9.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.977600.966526.959190
12.992390.970161.959171.951890
23.984838.962778.951872
34.977344.955452.944628
45.969906.948181
56.962526.940965
67.955201.933805
78.947932
89.940718
910.933560
1011.926455
1112.919405
12.912409

Table F(9.8)-With Interest at 9.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.977165.965878.958402
12.992239.969582.958382.950964
23.984539.962057.950945
34.976898.954591.943565
45.969317.947183
56.961795.939832
67.954331.932539
78.946924
89.939576
910.932284
1011.925049
1112.917870
12.910747

Table F(10.0)-With Interest at 10.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.976731.965232.957616
12.992089.969004.957596.950041
23.984240.961338.950021
34.976454.953733.942505
45.968729.946188
56.961066.938703
67.953463.931277
78.945920
89.938436
910.931012
1011.923647
1112.916340
12.909091

Table F(10.2)-With Interest at 10.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.976298.964588.956833
12.991939.968428.956812.949120
23.983943.960622.949099
34.976011.952878.941448
45.968143.945196
56.960338.937577
67.952597.930019
78.944918
89.937301
910.929745
1011.922250
1112.914816
12.907441

Table F(10.4)-With Interest at 10.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.975867.963946.956052
12.991789.967854.956031.948202
23.983645.959907.948181
34.975568.952025.940395
45.967558.944208
56.959613.936455
67.951734.928765
78.943919
89.936168
910.928481
1011.920858
1112.913296
12.905797

Table F(10.6)-With Interest at 10.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.975436.963305.955274
12.991639.967281.955252.947287
23.983349.959194.947265
34.975127.951174.939345
45.966974.943222
56.958890.935336
67.950873.927516
78.942923
89.935039
910.927222
1011.919470
1112.911782
12.904159

Table F(10.8)-With Interest at 10.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.975007.962667.954498
12.991490.966710.954475.946375
23.983052.958483.946352
34.974687.950327.938299
45.966392.942239
56.958168.934221
67.950014.926271
78.941930
89.933914
910.925966
1011.918086
1112.910273
12.902527

Table F(11.0)-With Interest at 11.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.974579.962030.953724
12.991341.966140.953700.945466
23.982757.957774.945442
34.974247.949481.937255
45.965811.941260
56.957449.933109
67.949158.925029
78.940939
89.932792
910.924715
1011.916708
1112.908770
12.900901

Table F(11.2)-With Interest at 11.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.974152.961395.952952
12.991192.965572.952927.944559
23.982462.957068.944534
34.973809.948638.936215
45.965232.940283
56.956731.932001
67.948304.923792
78.939952
89.931673
910.923467
1011.915333
1112.907272
12.899281

Table F(11.4)-With Interest at 11.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.973726.960762.952183
12.991044.965005.952157.943655
23.982168.956363.943630
34.973372.947798.935178
45.964654.939309
56.956015.930896
67.947452.922559
78.938967
89.930557
910.922223
1011.913964
1112.905778
12.897666

Table F(11.6)-With Interest at 11.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.973302.960130.951416
12.990896.964440.951389.942754
23.981874.955660.942728
34.972935.946959.934145
45.964077.938338
56.955300.929795
67.946603.921330
78.937985
89.929445
910.920984
1011.912599
1112.904290
12.896057

Table F(11.8)-With Interest at 11.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.972878.959501.950651
12.990748.963877.950624.941855
23.981582.954959.941828
34.972500.946124.933114
45.963502.937370
56.954588.928698
67.945756.920105
78.937006
89.928337
910.919748
1011.911238
1112.902807
12.894454

Table F(12.0)-With Interest at 12.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.972456.958873.949888
12.990600.963315.949860.940960
23.981289.954260.940932
34.972065.945290.932087
45.962928.936405
56.953877.927603
67.944911.918884
78.936029
89.927231
910.918515
1011.909882
1112.901329
12.892857

Table F(12.2)-With Interest at 12.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.972034.958247.949128
12.990453.962754.949099.940067
23.980997.953563.940038
34.971632.944460.931063
45.962356.935443
56.953168.926512
67.944069.917667
78.935056
89.926129
910.917287
1011.908530
1112.899856
12.891266

Table F(12.4)-With Interest at 12.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.971614.957623.948370
12.990306.962195.948340.939176
23.980706.952868.939147
34.971199.943631.930043
45.961785.934484
56.952461.925425
67.943228.916454
78.934085
89.925030
910.916063
1011.907183
1112.898389
12.889680

Table F(12.6)-With Interest at 12.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least but less than Annual period Semiannual period Quarterly period Monthly period
11.000000.971195.957000.947614
12.990159.961638.947583.938289
23.980416.952175.938258
34.970768.942805.929025
45.961215.933527
56.951756.924341
67.942390.915245
78.933117
89.923934
910.914842
1011.905840
1112.896926
12.888099

Table F(12.8)-With Interest at 12.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least but less than Annual period Semiannual period Quarterly period Monthly period
11.000000.970777.956379.946860
12.990013.961082.946828.937403
23.980126.951484.937372
34.970337.941981.928011
45.960647.932574
56.951053.923260
67.941554.914040
78.932151
89.922842
910.913625
1011.904501
1112.895468
12.886525

Table F(13.0)-With Interest at 13.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.970360.955760.946108
12.989867.960528.946075.936521
23.979836.950795.936489
34.969908.941160.926999
45.960079.931623
56.950351.922183
67.940721.912838
78.931188
89.921753
910.912412
1011.903167
1112.894015
12.884956

Table F(13.2)-With Interest at 13.2 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.969945.955143.945359
12.989721.959975.945325.935641
23.979548.950107.935608
34.969479.940341.925991
45.959514.930675
56.949651.921109
67.939889.911641
78.930228
89.920667
910.911203
1011.901837
1112.892567
12.883392

Table F(13.4)-With Interest at 13.4 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.969530.954527.944611
12.989575.959423.944577.934764
23.979260.949422.934730
34.969051.939524.924986
45.958949.929730
56.948953.920038
67.939060.910447
78.929271
89.919584
910.909998
1011.900511
1112.891124
12.881834

Table F(13.6)-With Interest at 13.6 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.969117.953913.943866
12.989430.958873.943831.933890
23.978972.948738.933854
34.968624.938710.923984
45.958386.928788
56.948256.918971
67.938233.909257
78.928316
89.918504
910.908796
1011.899190
1112.889686
12.880282

Table F(13.8)-With Interest at 13.8 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first full taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.968704.953301.943123
12.989285.958325.943087.933018
23.978685.948056.932982
34.968199.937898.922985
45.957824.927849
56.947561.917907
67.937408.908072
78.927364
89.917428
910.907598
1011.897873
1112.888252
12.878735

Table F(14.0)-With Interest at 14.0 Percent, Showing Factors for Computation of the Adjusted Payout Rate for Certain Valuations

[Applicable after April 30, 1989]

1
Number of months by which the valuation date for the first rull taxable year of the trust precedes the first payout
2
Factors for payout at the end of each period
At least But less than Annual period Semiannual period Quarterly period Monthly period
11.000000.968293.952691.942382
12.989140.957778.942345.932148
23.978399.947377.932111
34.967774.937088.921989
45.957264.926912
56.946868.916846
67.936586.906889
78.926415
89.916354
910.906403
1011.896560
1112.886824
12.877193

(7)Actuarial Table U(1) for transfers for which the valuation date is on or after June 1, 2023. The present value of a remainder interest in a charitable remainder unitrust that is dependent on the termination of a life interest is determined by using the section 7520 rate, Tables F(0.2) through (20.0) (see paragraph (e)(6)(ii) of this section), and the formula in paragraph (e)(5)(i) of this section to derive a remainder factor from the appropriate mortality table to at least five decimal places. For the convenience of taxpayers, actuarial factors have been computed by the IRS and appear in Table U(1). For transfers for which the valuation date is on or after June 1, 2023, the actuarial tables are currently available, at no charge, electronically via the IRS website at https://www.irs.gov/retirement-plans/actuarial-tables. These actuarial tables are referenced and explained by IRS Publication 1458, Actuarial Valuations Version 4B (2023). This publication will be available within a reasonable time after June 1, 2023. See, however, § 1.7520-3(b) (relating to exceptions to the use of prescribed tables under certain circumstances).
(f)Applicability date. This section applies on and after June 1, 2023.

26 C.F.R. §1.664-4

T.D. 8540, 59 FR 30117, June 10, 1994, as amended by T.D. 8819, 64 FR 23199, Apr. 30, 1999; T.D. 8886, 65 FR 36919 , 36943, June 12, 2000; T.D. 9448, 74 FR 21465 , May 7, 2009; T.D. 9540, 76 FR 49595 , Aug. 10, 2011; T.D. 9974, 88 FR 37433 , June 7, 2023
T.D. 9974, 88 FR 37433 , 6/1/2023