Internal Revenue Bulletin 2022-21 (PDF rendition): IRS Notices

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Bulletin No. 2022–21
May 23, 2022
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.
ADMINISTRATIVE, INCOME TAX
Rev. Proc. 2022-22, page 1098.
This revenue procedure provides two simplified proce-
dures for bona fide residents of Puerto Rico who are
not otherwise required to file taxable year 2021 Federal
tax returns, and who meet certain other requirements
(Puerto Rico CTC filers) to claim the child tax credit.
Under section 4 of this revenue procedure, Puerto Rico
CTC filers who file simplified U.S. self-employment tax
returns may omit their modified adjusted gross income
for the purpose of claiming the child tax credit. Under
section 5 of this revenue procedure, Puerto Rico CTC
filers who file simplified Federal income tax returns may
omit their modified adjusted gross income for the pur-
pose of claiming the child tax credit.
ESTATE TAX, GIFT TAX, INCOME TAX
REG-122770-18, page 1104.
These proposed regulations provide guidance relating
to the use of actuarial tables in valuing annuities, in-
terests for life or a term of years, and remainder or
reversionary interests. These regulations will affect
the valuation of inter vivos and testamentary transfers
of interests dependent on one or more measuring
lives. These regulations are necessary because sec-
tion 7520(c)(3) directs the Secretary to update the
actuarial tables to reflect the most recent mortality
experience available.
INCOME TAX
Notice 2022-20, page 1095.
This notice publishes the inflation adjustment factor and
reference price for calendar year 2022 for the renew-
able electricity production credit under section 45 of
the Internal Revenue Code. The notice also provides
the credit amounts for calendar year 2022 under
section 45.
Notice 2022-24, page 1097.
The notice announces that under § 613A(c)(6)(C) of the
Internal Revenue Code, the applicable percentage for
purposes of determining percentage depletion on mar-
ginal properties for calendar year 2022 is 15 percent.
The format of the notice is identical to the format of
notices previously published on this issue.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing of-
ficial 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.
It is the policy of the Service to publish in the Bulletin all sub-
stantive 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 other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
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 rul-
ings 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.
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 procedures 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.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, 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).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last 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 last Bulletin of each semiannual period.
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.
May 23, 2022 Bulletin No. 2022–21

Part III
Credit for Renewable
Electricity Production and
Publication of Inflation
Adjustment Factor and
Reference Price for
Calendar Year 2022
Notice 2022-20
This notice publishes the inflation ad-
justment factor and reference price for
calendar year 2022 for the renewable elec-
tricity production credit under section 45
of the Internal Revenue Code. The 2022
inflation adjustment factor and reference
price are used in determining the avail-
ability of the credit and apply to calendar
year 2022 sales of kilowatt hours of elec-
tricity produced in the United States or a
possession thereof from qualified energy
resources. For calendar year 2022, the
credit period for refined coal production
and Indian coal production expired.
BACKGROUND
Section 45(a) provides that the renew-
able electricity production credit for any
tax year is an amount equal to the prod-
uct of 1.5 cents multiplied by the kilowatt
hours of specified electricity produced
by the taxpayer and sold to an unrelated
person during the tax year. This electric-
ity must be produced from qualified en-
ergy resources and at a qualified facility
during the 10-year period beginning on
the date the facility was originally placed
in service.
Section 45(b)(1) provides that the
amount of the credit determined under
section 45(a) is reduced by an amount
which bears the same ratio to the amount
of the credit as (A) the amount by which
the reference price for the calendar year
in which the sale occurs exceeds 8 cents,
bears to (B) 3 cents. Under section 45(b)
(2), the 1.5 cent amount in section 45(a)
and the 8 cent amount in section 45(b)
(1) are each adjusted by multiplying such
amount by the inflation adjustment factor
for the calendar year in which the sale
occurs. If any amount as increased under
the preceding sentence is not a multiple
of 0.1 cent, the amount is rounded to the
nearest multiple of 0.1 cent. In the case of
electricity produced in open-loop biomass
facilities, landfill gas facilities, trash facil-
ities, qualified hydropower facilities, and
marine and hydrokinetic renewable ener-
gy facilities, section 45(b)(4)(A) requires
the amount in effect under section 45(a)
(1) (before rounding to the nearest 0.1
cent) to be reduced by one-half.
Section 45(b)(5) provides that in the
case of any facility using wind to produce
electricity, the amount of the credit deter-
mined under section 45(a) (determined af-
ter the application of section 45(b)(1), (2),
and (3) and without regard to section 45(b)
(5)) shall be reduced by (A) in the case
of any facility the construction of which
begins after December 31, 2016, and be-
fore January 1, 2018, 20 percent, (B) in
the case of any facility the construction of
which begins after December 31, 2017,
and before January 1, 2019, 40 percent,
(C) in the case of any facility the con-
struction of which begins after December
31, 2018, and before January 1, 2020, 60
percent, and (D) in the case of any facili-
ty the construction of which begins after
December 31, 2019, and before January 1,
2022, 40 percent.
Section 45(c)(1) defines qualified en-
ergy resources as wind, closed-loop bio-
mass, open-loop biomass, geothermal
energy, municipal solid waste, qualified
hydropower production, and marine and
hydrokinetic renewable energy.
Section 45(d)(1) defines a qualified
facility using wind to produce electricity
as any facility owned by the taxpayer that
is originally placed in service after De-
cember 31, 1993, and the construction of
which begins before January 1, 2022. See
section 45(e)(7) for rules relating to the
inapplicability of the credit to electricity
sold to utilities under certain contracts.
Section 45(d)(2)(A) defines a qualified
facility using closed-loop biomass to pro-
duce electricity as any facility (i) owned
by the taxpayer that is originally placed in
service after December 31, 1992, and the
construction of which begins before Janu-
ary 1, 2022, or (ii) owned by the taxpayer
which before January 1, 2022 is original-
ly placed in service and modified to use
closed-loop biomass to co-fire with coal,
with other biomass, or with both, but only
if the modification is approved under the
Biomass Power for Rural Development
Programs or is part of a pilot project of
the Commodity Credit Corporation as
described in 65 FR 63052. For purposes
of section 45(d)(2)(A)(ii), a facility shall
be treated as modified before January 1,
2022, if the construction of such modifica-
tion begins before such date. Section 45(d)
(2)(C) provides that in the case of a qual-
ified facility described in section 45(d)(2)
(A)(ii), (i) the 10-year period referred to
in section 45(a) is treated as beginning no
earlier than the date of the enactment of
section 45(d)(2)(C)(i) (October 22, 2004),
and (ii) if the owner of such facility is not
the producer of the electricity, the person
eligible for the credit allowable under
section 45(a) is the lessee or the operator
of such facility. A qualified facility using
closed-loop biomass includes a new unit
placed in service after the date of the en-
actment of section 45(d)(2)(B) (October 3,
2008) in connection with a qualified facil-
ity using closed-loop biomass, but only to
the extent of the increased amount of elec-
tricity produced at the facility by reason of
such new unit.
Section 45(d)(3)(A) defines a quali-
fied facility using open-loop biomass to
produce electricity as any facility owned
by the taxpayer which (i) in the case of a
facility using agricultural livestock waste
nutrients, (I) is originally placed in service
after the date of the enactment of section
45(d)(3)(A)(i)(I) (October 22, 2004) and
the construction of which begins before
January 1, 2022, and (II) the nameplate
capacity rating of which is not less than
150 kilowatts, and (ii) in the case of any
other facility, the construction of which
begins before January 1, 2022. In the case
of any facility described in section 45(d)
(3)(A), if the owner of such facility is not
the producer of the electricity, section
45(d)(3)(C) provides that the person eligi-
ble for the credit allowable under section
45(a) is the lessee or the operator of such
facility. A qualified facility using open-
loop biomass includes a new unit placed
Bulletin No. 2022–21 1095 May 23, 2022

in service after the date of the enactment
of section 45(d)(3)(B) (October 3, 2008)
in connection with a qualified facility us-
ing open-loop biomass, but only to the ex-
tent of the increased amount of electricity
produced at the facility by reason of such
new unit.
Section 45(d)(4) defines a qualified
facility using geothermal energy to pro-
duce electricity as any facility owned by
the taxpayer that is originally placed in
service after the date of the enactment of
section 45(d)(4) (October 22, 2004) and
the construction of which begins before
January 1, 2022. A qualified facility using
geothermal energy does not include any
property described in section 48(a)(3) the
basis of which is taken into account by the
taxpayer for purposes of determining the
energy credit under section 48.
Section 45(d)(6) defines a qualified
facility using gas derived from the bio-
degradation of municipal solid waste to
produce electricity as any facility owned
by the taxpayer that is originally placed in
service after the date of the enactment of
section 45(d)(6) (October 22, 2004) and
the construction of which begins before
January 1, 2022.
Section 45(d)(7) defines a qualified
facility (other than a facility described in
section 45(d)(6)) that uses municipal solid
waste to produce electricity as any facility
owned by the taxpayer that is originally
placed in service after the date of the en-
actment of section 45(d)(7) (October 22,
2004) and the construction of which be-
gins before January 1, 2022. A qualified
facility using municipal solid waste in-
cludes a new unit placed in service in con-
nection with a facility placed in service on
or before the date of the enactment of sec-
tion 45(d)(7), but only to the extent of the
increased amount of electricity produced
at the facility by reason of such new unit.
Section 45(d)(9) defines a qualified
facility producing qualified hydroelectric
production described in section 45(c)(8)
as (i) any facility producing incremental
hydropower production, but only to the
extent of its incremental hydropower pro-
duction attributable to efficiency improve-
ments or additions to capacity described in
section 45(c)(8)(B) placed in service after
the date of the enactment of section 45(d)
(9) (August 8, 2005) and before January
1, 2022, and (ii) any other facility placed
in service after the date of the enactment
of section 45(d)(9) (August 8, 2005) and
the construction of which begins before
January 1, 2022. Section 45(d)(9)(B) pro-
vides that, in the case of a qualified facil-
ity described in section 45(d)(9)(A), the
10-year period referred to in section 45(a)
shall be treated as beginning on the date
the efficiency improvements or additions
to capacity are placed in service. Section
45(d)(9)(C) provides that for purposes of
section 45(d)(9)(A)(i), an efficiency im-
provement or addition to capacity shall be
treated as placed in service before January
1, 2022 if the construction of such im-
provement or addition begins before such
date.
Section 45(d)(11) provides in the case
of a facility producing electricity from
marine and hydrokinetic renewable ener-
gy, the term “qualified facility” means any
facility owned by the taxpayer which (A)
has a nameplate capacity rating of at least
150 kilowatts, and (B) is originally placed
in service on or after the date of the en-
actment of section 45(d)(11) (October 3,
2008) and the construction of which be-
gins before January 1, 2022.
Section 45(e)(2)(A) requires the Secre-
tary to determine and publish in the Feder-
al Register each calendar year the inflation
adjustment factor and the reference price
for such calendar year. The inflation ad-
justment factor and the reference price for
the 2022 calendar year were published in
the Federal Register at 87 FR 22286 on
April 14, 2022. A Correction notice was
published in the Federal Register at 87 FR
27204 on May 6, 2022.
Section 45(e)(2)(B) defines the infla-
tion adjustment factor for a calendar year
as a fraction the numerator of which is the
GDP implicit price deflator for the pre-
ceding calendar year and the denominator
of which is the GDP implicit price defla-
tor for the calendar year 1992. The term
“GDP implicit price deflator” means the
most recent revision of the implicit price
deflator for the gross domestic product as
computed and published by the Depart-
ment of Commerce before March 15 of
the calendar year.
Section 45(e)(2)(C) provides that the
reference price is the Secretary’s determi-
nation of the annual average contract price
per kilowatt hour of electricity generated
from the same qualified energy resource
and sold in the previous year in the United
States. Only contracts entered into after
December 31, 1989 are taken into account.
INFLATION ADJUSTMENT
FACTOR AND REFERENCE PRICE
The inflation adjustment factor for cal-
endar year 2022 for qualified energy re-
sources is 1.7593.
The reference price for calendar year
2022 for facilities producing electricity
from wind (based upon information pro-
vided by the Department of Energy) is
4.09 cents per kilowatt hour. The reference
prices for facilities producing electricity
from closed-loop biomass, open-loop bio-
mass, geothermal energy, municipal solid
waste, qualified hydropower production,
and marine and hydrokinetic energy have
not been determined for calendar year
2022.
PHASEOUT CALCULATION
Because the 2022 reference price for
electricity produced from wind (4.09 cents
per kilowatt hour) does not exceed 8 cents
multiplied by the inflation adjustment fac-
tor (1.7593), the phaseout of the credit
provided in section 45(b)(1) does not ap-
ply to such electricity sold during calen-
dar year 2022. However, refer to section
45(b)(5) for an additional phaseout of the
credit for wind facilities the construction
of which begins after December 31, 2016.
For electricity produced from closed-loop
biomass, open-loop biomass, geothermal
energy, municipal solid waste, qualified
hydropower production, and marine and
hydrokinetic energy, the phaseout of the
credit provided in section 45(b)(1) does
not apply to such electricity sold during
calendar year 2022.
CREDIT AMOUNT BY QUALIFIED
ENERGY RESOURCE AND
FACILITY
As required by section 45(b)(2), the 1.5
cent amount in section 45(a)(1) is adjusted
by multiplying such amount by the infla-
tion adjustment factor for the calendar year
in which the sale occurs. If any amount as
increased under the preceding sentence is
not a multiple of 0.1 cent, such amount
is rounded to the nearest multiple of 0.1
May 23, 2022 1096 Bulletin No. 2022–21

Bulletin No. 2022–21 1097 May 23, 2022
cent. In the case of electricity produced in
open-loop biomass facilities, landfill gas
facilities, trash facilities, qualified hydro-
power facilities, and marine and hydroki-
netic renewable energy facilities, section
45(b)(4)(A) requires the amount in effect
under section 45(a)(1) (before rounding to
the nearest 0.1 cent) to be reduced by one-
half. Under the calculation required by
section 45(b)(2), the credit for renewable
electricity production for calendar year
2022 under section 45(a) is 2.6 cents per
kilowatt hour on the sale of electricity pro-
duced from the qualified energy resources
of wind, closed-loop biomass, and geo-
thermal energy, and 1.3 cents per kilowatt
hour on the sale of electricity produced in
open-loop biomass facilities, landfill gas
facilities, trash facilities, qualified hydro-
power facilities, and marine and hydroki-
netic energy facilities.
DRAFTING AND CONTACT
INFORMATION
The principal author of this notice is
Charles Hyde of the Office of Associate
Chief Counsel (Passthroughs & Special
Industries). For further information re-
garding this notice contact Mr. Hyde at
(202) 317-6853 (not a toll-free number).
2022 Marginal Production
Rates
Notice 2022-24
This notice announces the applicable
percentage under § 613A of the Internal
Revenue Code to be used in determining
percentage depletion for marginal proper-
ties for the 2022 calendar year.
Section 613A(c)(6)(C) defines the term
“applicable percentage” for purposes of
determining percentage depletion for oil
and gas produced from marginal prop-
erties. The applicable percentage is the
percentage (not greater than 25 percent)
equal to the sum of 15 percent, plus one
percentage point for each whole dollar
by which $20 exceeds the reference price
(determined under § 45K(d)(2)(C)) for
crude oil for the calendar year preceding
the calendar year in which the taxable year
begins. The reference price determined
under § 45K(d)(2)(C) for the 2021 calen-
dar year is $65.90.
The following table contains the appli-
cable percentages for marginal production
for taxable years beginning in calendar
years 1991 through 2022.
Notice 2022-24
APPLICABLE PERCENTAGE FOR MARGINAL
PRODUCTION
Calendar YearApplicable Percentage
199115 percent
199218 percent
199319 percent
199420 percent
199521 percent
199620 percent
199716 percent
199817 percent
199924 percent
200019 percent
200115 percent
200215 percent
200315 percent
200415 percent
200515 percent
200615 percent
200715 percent
200815 percent
200915 percent
201015 percent
201115 percent
201215 percent
201315 percent

May 23, 2022 1098 Bulletin No. 2022–21
Notice 2022-24
APPLICABLE PERCENTAGE FOR MARGINAL
PRODUCTION
Calendar YearApplicable Percentage
201415 percent
201515 percent
201615 percent
201715 percent
201815 percent
201915 percent
202015 percent
202115 percent
202215 percent
The principal author of this notice
is Elimelech Brander of the Office of
Associate Chief Counsel (Passthroughs
and Special Industries). For further infor-
mation regarding this notice contact Mr.
Brander at (202) 317-6853 (not a toll-free
number).
26 CFR 1.6012-1: Individuals required to make
returns of income.
(Also Part I, §§ 24, 933, 7527A; 1.933-1.)
Rev. Proc. 2022-22
SECTION 1. PURPOSE
.01 This revenue procedure provides
simplified procedures for certain bona fide
residents of the Commonwealth of Puerto
Rico (Puerto Rico) to claim the child tax
credit under § 24.
1
The Department of the
Treasury and the Internal Revenue Service
(IRS) have provided these procedures to
make it easier for certain bona fide resi-
dents of Puerto Rico to file taxable year
2021 Federal tax returns to claim the child
tax credit.
.02 Section 2 of this revenue procedure
describes the child tax credit in further de-
tail. Section 3 of this revenue procedure
describes the scope of the procedures
provided in this revenue procedure. Sec-
tion 4 of this revenue procedure provides
a simplified procedure for filing Form
1040-PR, Planilla para la Declaración
de la Contribución Federal sobre el Tra-
bajo por Cuenta Propia, or Form 1040-
SS, U.S. Self-Employment Tax Return, to
claim the child tax credit. Section 5 of this
revenue procedure provides a simplified
procedure for filing Form 1040, U.S. Indi-
vidual Income Tax Return (also available
as Formulario 1040(SP), Declaración de
Impuestos de los Estados Unidos Sobre los
Ingresos Personales), or Form 1040-SR,
U.S. Tax Return for Seniors (also available
as Formulario 1040-SR(SP), Declaración
de Impuestos de los Estados Unidos para
Personas de 65 Años de Edad o Más), to
claim the child tax credit.
SECTION 2. BACKGROUND
.01 Overview of 2021 Child Tax Cred-
it. Section 9611 of the American Rescue
Plan Act of 2021 (American Rescue Plan),
Public Law 117-2, 135 Stat. 4, 144-149
(March 11, 2021), added §§ 24(i), 24(j),
and 7527A to the Code. Section 24(i)
modifies the child tax credit rules set forth
in § 24 for any taxable year beginning af-
ter December 31, 2020, and before Janu-
ary 1, 2022 (taxable year 2021). Section
7527A provides for advance payments of
the child tax credit and section 24(j) pro-
vides that the amount of the child tax cred-
it is generally reduced by these advance
payments. Section 9612(a) of the Amer-
ican Rescue Plan added § 24(k) to the
Code to provide special rules for Amer-
ican Samoa, Guam, the Commonwealth
of the Northern Mariana Islands, Puerto
Rico, and the U.S. Virgin Islands (each, a
U.S. territory), effective for taxable years
beginning after December 31, 2020. 135
Stat. at 150-152.
.02 Credit Allowed. Under § 24(a),
a taxpayer may claim a child tax credit
against the taxpayer’s Federal income tax
(as imposed by chapter 1 of the Code) for
the taxable year with respect to each CTC
qualifying child (as defined in section 2.06
of this revenue procedure) of the taxpayer.
.03 Expanded Credit Eligibility for
Bona Fide Residents of Puerto Rico. Start-
ing in 2021, a bona fide resident of Puerto
Rico with one or more CTC qualifying
children may claim the child tax credit.
See §§ 24(i)(1) and 24(k)(2). Prior to en-
actment of the American Rescue Plan, §
24(d)(1)(B) required bona fide residents
of Puerto Rico who had no earned income
for Federal income tax purposes to have
at least three CTC qualifying children as
a condition for child tax credit eligibility.
.04 Credit Fully Refundable. The child
tax credit for taxable year 2021 is fully
refundable for a taxpayer if the taxpay-
er (or spouse, if filing a joint return) is a
bona fide resident of Puerto Rico (within
the meaning of § 937(a)) for such taxable
year. See § 24(i)(1). Full refundability
means that taxpayers can benefit from
the maximum amount of the credit even
1
Unless otherwise specified, all Code, section, and “§” references are to sections of the U.S. Internal Revenue Code (Code).

Bulletin No. 2022–21 1099 May 23, 2022
if they do not have taxable earned income
or do not owe any Federal tax for taxable
year 2021. Bona fide residents of Puerto
Rico may claim the fully refundable child
tax credit for taxable year 2021 even if
they had no income and paid no U.S. So-
cial Security taxes.
.05 Credit Amounts. Taxpayers claim-
ing the child tax credit for taxable year
2021 may receive up to $3,000 for each
CTC qualifying child who is between the
ages of 6 and 17 as of the end of taxable
year 2021, and $3,600 for each CTC qual-
ifying child who is under the age of 6 as of
the end of taxable year 2021. See § 24(i)
(2) and (3). The child tax credit for taxable
year 2021 begins to be reduced if modified
adjusted gross income (AGI) for purposes
of the child tax credit exceeds $150,000
if filing a joint return or if filing as a sur-
viving spouse (as defined in § 2(a) of the
Code); $112,500 if filing as head of house-
hold (as defined in § 2(b)); or $75,000 if
filing as single or married and filing a sep-
arate return. See § 24(i)(4).
.06 CTC Qualifying Child. A “CTC
qualifying child” is a qualifying child
of the taxpayer (as defined in § 152(c))
who has not attained the age of 18 at the
close of taxable year 2021. See § 24(i)(2)
(A). No child tax credit is allowed for a
qualifying child unless the social security
number (SSN) of the child, which must
be valid for employment and be issued by
the Social Security Administration before
the due date of the taxpayer’s taxable year
Federal income tax return (including ex-
tensions), is provided on the return. See §
24(h)(7). If the taxpayer’s child was a U.S.
citizen when the child received the SSN,
the SSN is valid for employment.
.07 Advance Child Tax Credit Pay-
ments for Calendar Year 2021. Section
7527A(a) required the Secretary of the
Treasury or her delegate to establish a pro-
gram for making periodic advance child
tax credit payments to taxpayers the total
of which, during any calendar year, equals
the “annual advance amount” (as defined
in § 7527A(b)(1)) determined with respect
to that taxpayer for that calendar year. Al-
though residents of Puerto Rico may be
eligible to claim the child tax credit, res-
idents of Puerto Rico were not eligible to
receive advance child tax credit payments.
See § 7527A(e)(4)(A). However, there
may have been circumstances in which
a resident of Puerto Rico nonetheless re-
ceived advance child tax credit payments
(for example, if the IRS estimated the
Puerto Rico resident’s child tax credit for
taxable year 2021 based on a Form 1040
or Form 1040-SR that the resident filed for
taxable year 2019 or 2020).
.08 Reconciliation Requirement Re-
garding Child Tax Credit and Advance
Child Tax Credit Payments. Bona fide
residents of Puerto Rico who received
advance child tax credit payments (de-
scribed in section 2.07 of this revenue
procedure) during calendar year 2021
must reduce (but not below zero) the
amount of the child tax credit claimed
for taxable year 2021 by the total amount
of those advance child tax credit pay-
ments. See § 24(j)(1). If the amount of
the taxpayer’s advance child tax credit
payments received in calendar year 2021
exceeds the taxpayer’s allowable child
tax credit for taxable year 2021, the tax-
payer’s Federal income tax imposed for
taxable year 2021 will be increased by
the excess subject to reduction by a “safe
harbor amount.” See § 24(j)(2).
SECTION 3. SCOPE
.01 Overview. This revenue procedure
allows Puerto Rico CTC filers (as defined
in section 4.02 of this revenue procedure)
to provide information to the IRS to claim
the child tax credit through the filing of a
simplified Federal tax return using either
of the following procedures: (1) the proce-
dures set forth in section 4 of this revenue
procedure, which allow Puerto Rico CTC
filers to provide this information through
a simplified Form 1040-PR or Form 1040-
SS or (2) the procedures set forth in sec-
tion 5 of this revenue procedure, which al-
low Puerto Rico CTC filers to provide this
information through a simplified Form
1040 or Form 1040-SR.
.02 Purpose of Simplified Filing Pro-
cedure under Section 4. Section 4 of this
revenue procedure provides a simplified
filing procedure that permits Puerto Rico
CTC filers to file a Form 1040-PR or Form
1040-SS to claim the child tax credit. Spe-
cifically, Puerto Rico CTC filers who file
a simplified Form 1040-PR or Form 1040-
SS for taxable year 2021 in accordance
with section 4 of this revenue procedure
do not need to specify their income to
compute the amount of child tax credit
that they are eligible to claim.
.03 Purpose of Simplified Filing Pro-
cedure under Section 5. Section 5 of this
revenue procedure provides a simplified
filing procedure that permits Puerto Rico
CTC filers to file a Form 1040 or Form
1040-SR to claim the child tax credit. Spe-
cifically, Puerto Rico CTC filers who file
a simplified Form 1040 or Form 1040-SR
for taxable year 2021 in accordance with
section 5 of this revenue procedure do not
need to specify their income to compute
the amount of child tax credit that they are
eligible to claim.
.04 Individuals Who Are Not Puerto
Rico Residents Are Not Eligible. The pro-
cedures provided by this revenue proce-
dure apply only to a U.S. citizen or U.S.
resident alien who is a bona fide resident
of Puerto Rico and who is not described in
section 3.05, 3.06, 3.07, or 3.08 of this rev-
enue procedure. The procedures provided
by this revenue procedure do not apply to
a resident of any U.S. territory (as defined
in section 2.01 of this revenue procedure)
other than Puerto Rico, or to a U.S. citizen
or U.S. resident who is not a resident of a
U.S. territory. Residents of a U.S. territo-
ry should contact their local territory tax
agency for additional information about
the child tax credit. A U.S. citizen or U.S.
resident who is not a resident of a U.S. ter-
ritory should refer to Form 1040 or Form
1040-SR, Schedule 8812 (Form 1040),
Credits for Qualifying Children and Oth-
er Dependents, and their instructions, to
claim the child tax credit for taxable year
2021. A U.S. citizen or U.S. resident alien
who is not a bona fide resident of Puerto
Rico or a resident of a U.S. territory may
qualify to use the simplified filing pro-
cedures set forth in Rev. Proc. 2022-12,
2022-7 I.R.B. 494. See section 4.02(1) and
(6) of this revenue procedure.
.05 Individuals Required to File a
Form 1040-PR, Form 1040-SS, Form
1040, or Form 1040-SR Not Eligible. The
procedures provided by this revenue pro-
cedure do not apply to individuals who
are required to file a Form 1040-PR, Form
1040-SS, Form 1040, or Form 1040-SR
for taxable year 2021 (including bona fide
residents of Puerto Rico who are required
to report tax on their self-employment in-
come). See section 4.02(2) and (3) of this
revenue procedure.

May 23, 2022 1100 Bulletin No. 2022–21
.06 Individuals With Modified AGI
Above Applicable Income Thresholds
Not Eligible. The procedures provided
by this revenue procedure do not apply to
individuals whose modified AGI for pur-
poses of the child tax credit exceeds the
applicable income threshold for claiming
the maximum child tax credit amount as
described in section 2.05 of this revenue
procedure. That is, the procedures do
not apply to individuals whose modified
AGI exceeds (i) $150,000, if filing a joint
return or filing as a surviving spouse;
(ii) $112,500, if filing as head of house-
hold; and (iii) $75,000, if filing as single
or married and filing a separate return. The
amount of income of an individual with
modified AGI at or below their applica-
ble threshold will not impact the amount
of the child tax credit that the individual
is eligible to claim. See section 4.02(4) of
this revenue procedure.
.07 Individuals Who Received Excess
Advance Child Tax Credit Payments Not
Eligible. The procedures provided by this
revenue procedure apply to individuals
who need to file a Federal income tax
return to claim the child tax credit in an
amount greater than zero for taxable year
2021. Individuals who received advance
child tax credit payments during calen-
dar year 2021, the total amount of which
equals or exceeds the individual’s allow-
able child tax credit for taxable year 2021,
cannot claim the child tax credit in an
amount greater than zero for taxable year
2021. Accordingly, the procedures provid-
ed by this revenue procedure do not apply
to such individuals, and they cannot file a
Federal tax return under this revenue pro-
cedure. See section 4.02(5) of this revenue
procedure.
.08 Individuals Who Previously Filed
a Form 1040-PR, Form 1040-SS, Form
1040, or Form 1040-SR Not Eligible. The
procedures provided by this revenue pro-
cedure do not apply to individuals who
have already filed a paper or electronic
Form 1040-PR, Form 1040-SS, Form
1040, or Form 1040-SR for taxable year
2021. Such individuals do not need to file
any additional forms or otherwise contact
the IRS to claim the child tax credit for
each CTC qualifying child if the child tax
credit was claimed on the previously filed
return for taxable year 2021. See section
4.02(7) of this revenue procedure.
SECTION 4. SPECIAL PROCEDURE
FOR PUERTO RICO CTC FILERS
TO FILE FORM 1040-PR OR FORM
1040-SS TO CLAIM THE CHILD
TAX CREDIT
.01 Federal Tax Return Claiming the
Child Tax Credit. Under the simplified
procedure set forth in this section 4, a
simplified return may be filed, on paper or
electronically, for taxable year 2021 on a
Form 1040-PR or Form 1040-SS. A Fed-
eral tax return for taxable year 2021 filed
by a Puerto Rico CTC filer under the sim-
plified procedure in this section 4 will re-
sult in the Puerto Rico CTC filer claiming
the child tax credit for taxable year 2021.
.02 Definition of Puerto Rico CTC
Filer. For purposes of this revenue pro-
cedure, a “Puerto Rico CTC filer” is an
individual--
(1) Who is a bona fide resident of Puer-
to Rico (within the meaning of § 937(a)
for taxable year 2021);
(2) Whose income for taxable year
2021 is completely exempt from taxation
under § 933;
(3) Who is not required to file a Form
1040-PR, Form 1040-SS, Form 1040,
or Form 1040-SR for taxable year 2021,
such as to report tax on self-employment
income;
(4) Whose modified AGI for taxable
year 2021 under § 24(b)(1) is less than or
equal to their applicable income threshold
under § 24(i)(4)(B);
(5) Who is eligible to claim the child
tax credit in an amount greater than zero
for taxable year 2021;
(6) Who is a U.S. citizen or resident
alien (or is treated as a United States res-
ident alien in accordance with an election
under § 6013(g) or (h)); and
(7) Who has not already filed a paper or
electronic Form 1040-PR, Form 1040-SS,
Form 1040, or Form 1040-SR for taxable
year 2021.
.03 Simplified Filing Method.
(1) Overview. In the case of a Puerto
Rico CTC filer, the IRS will process the
filer’s Form 1040-PR or Form 1040-SS
for taxable year 2021 to calculate the
child tax credit if the form is prepared in
the manner required by this section 4.03.
The Form 1040-PR or Form 1040-SS
must include the information described
in this section 4.03 to claim the child tax
credit. The information described in this
section 4.03 generally follows the stan-
dard IRS instructions except that a Puerto
Rico CTC filer is not required to report the
filer’s modified AGI on line 1 of Part II. A
Puerto Rico CTC filer may file a Sched-
ule LEP (Form 1040), Request for Change
in Language Preference (also available
as Anexo LEP (Formulario 1040(SP)),
Solicitud para Cambiar la Preferencia
de Idioma), with Form 1040-PR or Form
1040-SS to request a change in language
preference for further communications
from the IRS.
(2) Personal information. A Puerto
Rico CTC filer must enter their name,
mailing address, and SSN or IRS Indi-
vidual Taxpayer Identification Number
(ITIN), and the name and SSN or ITIN of
their spouse if filing a joint return, at the
top of Form 1040-PR or Form 1040-SS.
(3) Virtual currency. A Puerto Rico
CTC filer must check the appropriate box
indicating whether the filer (either filer if
filing a joint return) received, sold, ex-
changed, or otherwise disposed of a finan-
cial interest in any virtual currency.
(4) Part I, line 1 (filing status). A Puer-
to Rico CTC filer must select their filing
status for taxable year 2021 on line 1 of
Part I.
(5) Part I, line 2 (CTC qualifying chil-
dren). A Puerto Rico CTC filer must com-
plete the appropriate lines on line 2 of Part
I regarding each CTC qualifying child for
taxable year 2021 who has an SSN that is
valid for employment. For each individ-
ual claimed as a CTC qualifying child,
the Puerto Rico CTC filer must provide
the name, SSN, and relationship to the
individual.
(6) Part I, lines 3 through 8. A Puerto
Rico CTC filer must leave lines 3 through
8 of Part I blank.
(7) Part I, line 9 (child tax credit en-
try). A Puerto Rico CTC filer must com-
plete line 9 of Part I. To determine this
amount, the Puerto Rico CTC filer must:
(a) Compute the sum of the following:
(i) $3,600 multiplied by the number of
CTC qualifying children of the filer listed
on line 2 of Part I who were under age 6 at
the end of taxable year 2021; and
(ii) $3,000 multiplied by the number of
CTC qualifying children of the filer listed
on line 2 of Part I who were under age 18
at the end of taxable year 2021 but who

Bulletin No. 2022–21 1101 May 23, 2022
were not under age 6 at the end of taxable
year 2021;
(b) Subtract from that sum the aggre-
gate amount of advance child tax credit
payments the filer (and the filer’s spouse
if filing jointly) received for 2021, if any,
which may be obtained from the filer’s
Letter 6419 or the filer’s IRS online ac-
count at https://www.irs.gov/account and,
as applicable, Letter 6419 of the filer’s
spouse or the IRS online account of the
filer’s spouse; and
(c) Enter that result on line 9 of Part I.
(8) Part I, lines 10 through 11b. A
Puerto Rico CTC filer must leave lines 10
through 11b of Part I blank.
(9) Part I, lines 12 through 14a. A
Puerto Rico CTC filer must enter on lines
12 through 14a of Part I the amount en-
tered on line 9 of Part I.
(10) Part I, line 14a checkbox (split
direct deposit indicator). A Puerto Rico
CTC filer may not check the box on line
14a of Part I.
(11) Part I, lines 14b through 14d (di-
rect deposit information). A Puerto Rico
CTC filer may request the direct deposit
of their taxable year 2021 tax refund into
an account at a bank or other financial in-
stitution by entering the information on
lines 14b through 14d of Part I. The Puerto
Rico CTC filer must not request that their
taxable year 2021 tax refund be deposit-
ed into an account that is not in the name
of that filer (for example, a Puerto Rico
CTC filer must not request a direct deposit
of their taxable year 2021 tax refund into
their tax return preparer’s account).
(12) Part I, lines 15 and 16. A Puerto
Rico CTC filer must leave lines 15 and 16
of Part I blank.
(13) Part II, line 1 (modified adjusted
gross income). A Puerto Rico CTC filer
must leave line 1 of Part II blank.
(14) Part II, line 3 (refundable child
tax credit). A Puerto Rico CTC filer must
enter on line 3 of Part II the amount en-
tered on line 9 of Part I.
(15) Parts III through VI. A Puerto Rico
CTC filer must leave Parts III through VI
blank.
(16) Signature. A Puerto Rico CTC
filer must sign the return under penalties
of perjury, including the filer’s identity
protection personal identification number
(that is, the filer’s IP PIN), if applicable,
as part of the filer’s signature. In addition,
the Puerto Rico CTC filer may enter the
identifying information of any third-party
designee, if applicable, at the bottom of
page 1 of Form 1040-PR or Form 1040-
SS. A Puerto Rico CTC filer who has been
assigned an IP PIN, but has misplaced
it, may retrieve the IP PIN at https://
www.irs.gov/identity-theft-fraud-scams/
retrieve-your-ip-pin.
.04 Simplified Return Is a Federal Tax
Return. A simplified return completed by a
Puerto Rico CTC filer in accordance with
the procedure described in section 4.03 of
this revenue procedure is a taxable year
2021 Federal tax return for all purposes,
whether filed on paper or electronically.
SECTION 5. SPECIAL PROCEDURE
FOR PUERTO RICO CTC FILERS
TO FILE FORM 1040 OR FORM
1040-SR TO CLAIM THE CHILD
TAX CREDIT
.01 Federal Tax Return Claiming the
Child Tax Credit. Under the simplified
procedure set forth in this section 5, a
simplified return may be filed, on paper or
electronically, for taxable year 2021 on a
Form 1040 or Form 1040-SR. A Federal
tax return for taxable year 2021 filed by
a Puerto Rico CTC filer under the simpli-
fied procedure in this section 5 will result
in the Puerto Rico CTC filer claiming the
child tax credit for taxable year 2021.
.02 Definition of Puerto Rico CTC Fil-
er. For purposes of this section 5, a “Puerto
Rico CTC filer” has the same definition as
in section 4.02 of this revenue procedure.
.03 Simplified Filing Method.
(1) Overview. In the case of a Puerto
Rico CTC filer, the IRS will process the
filer’s Form 1040 or Form 1040-SR for
taxable year 2021 to calculate the child
tax credit for taxable year 2021 if the form
is prepared in the manner required by this
section 5.03. The Form 1040 or Form
1040-SR must include the information
described in this section 5.03 to claim the
child tax credit. The information described
in this section 5.03 generally follows the
standard IRS instructions for filers whose
income is completely exempt from taxa-
tion under § 933 except that a Puerto Rico
CTC filer is not required to report the fil-
er’s modified AGI on lines 1 through 3
of Schedule 8812 (Form 1040). A Puerto
Rico CTC filer may file a Schedule LEP
(Form 1040) with Form 1040 or Form
1040-SR to request a change in language
preference for further communications
from the IRS.
(2) Required general information on
Form 1040 or Form 1040-SR.
(a) Filing status. A Puerto Rico CTC
filer must select their filing status for tax-
able year 2021 at the top of Form 1040 or
Form 1040-SR.
(b) Personal information. A Puerto
Rico CTC filer must enter their name,
mailing address, and SSN or ITIN, and
the name and SSN or ITIN of their spouse
if filing a joint return, on the appropriate
lines of Form 1040 or Form 1040-SR.
(3) Virtual currency. A Puerto Rico
CTC filer must check the appropriate box
on Form 1040 or Form 1040-SR indicat-
ing whether the filer (either filer if filing a
joint return) received, sold, exchanged, or
otherwise disposed of a financial interest
in any virtual currency.
(4) Individuals who could be claimed
as dependents by other individuals. A
Puerto Rico CTC filer must check the ap-
plicable boxes in the top line of the “Stan-
dard Deduction” section of the Form 1040
or Form 1040-SR for each individual who
can be claimed as a dependent by any oth-
er individual for taxable year 2021.
(5) General information regarding
dependents.
(a) In general. A Puerto Rico CTC fil-
er must complete the appropriate lines in
the “Dependents” section of Form 1040 or
Form 1040-SR regarding each CTC quali-
fying child for taxable year 2021 who has
an SSN that is valid for employment. For
each individual claimed as a CTC qualify-
ing child, the Puerto Rico CTC filer must
provide the name, SSN, and relationship
to the individual.
(b) CTC qualifying children. A Puerto
Rico CTC filer must check the child tax
credit box in Column (4) of the “Depen-
dents” section for each CTC qualifying
child for taxable year 2021 who has an
SSN that is valid for employment.
(6) Limited information to provide
in Form 1040 or Form 1040-SR, lines 1
through 38. A Puerto Rico CTC filer must
leave blank lines 1 through 38 of Form
1040 or Form 1040-SR, except as provid-
ed in this section 5.03(6):
(a) Line 28 (child tax credit entry).
A Puerto Rico CTC filer must enter

May 23, 2022 1102 Bulletin No. 2022–21
the amount of the filer’s child tax cred-
it for taxable year 2021 on line 28. The
credit amount may be computed using
Schedule 8812 (Form 1040), available at
https://www.irs.gov/Schedule8812 (also
available as Anexo 8812 (Formulario
1040(SP)), Créditos por Hijos Calificados
y Otros Dependientes, at https://www.irs.
gov/Schedule8812SP), and information
from the filer’s Letter 6419 or the filer’s
IRS online account at https://www.irs.gov/
account and, as applicable, Letter 6419 of
the filer’s spouse or the IRS online ac-
count of the filer’s spouse. The filer claim-
ing the child tax credit must (i) complete
Schedule 8812 pursuant to the instructions
described in section 5.03(8) through (22)
of this revenue procedure, and (ii) attach
the Schedule 8812 to the filer’s Form 1040
or Form 1040-SR.
(b) Lines 32 through 35a. A Puerto Rico
CTC filer must enter on lines 32 through
35a the amount entered on line 28.
(c) Line 35a checkbox (split direct de-
posit indicator). A Puerto Rico CTC filer
may not check the box on line 35a.
(d) Lines 35b through 35d (direct de-
posit information). A Puerto Rico CTC
filer may request the direct deposit of their
taxable year 2021 tax refund into an ac-
count at a bank or other financial institu-
tion by entering the information on lines
35b through 35d. The Puerto Rico CTC
filer must not request that their taxable
year 2021 tax refund be deposited into an
account that is not in the name of that fil-
er (for example, a Puerto Rico CTC filer
must not request a direct deposit of their
taxable year 2021 tax refund into their tax
return preparer’s account).
(7) Signature. A Puerto Rico CTC filer
must sign the Form 1040 or Form 1040-SR
under penalties of perjury, including the
filer’s identity protection personal identi-
fication number (that is, the filer’s IP PIN),
if applicable, as part of the filer’s signature.
In addition, the Puerto Rico CTC filer may
enter the identifying information of any
third-party designee, if applicable, at the
bottom of page 2 of Form 1040 or Form
1040-SR. A Puerto Rico CTC filer who
has been assigned an IP PIN, but has mis-
placed it, may retrieve the IP PIN at https://
www.irs.gov/identity-theft-fraud-scams/
retrieve-your-ip-pin.
(8) Schedule 8812. A Puerto Rico CTC
filer must enter the filer’s name and SSN
and the name of their spouse if filing a
joint return at the top of Schedule 8812.
(9) Schedule 8812, Part I-A, lines 1
through 3 (modified AGI). A Puerto Rico
CTC filer must leave lines 1 through 3 of
Schedule 8812 (Form 1040) blank.
(10) Schedule 8812, Part I-A, lines
4a-c (CTC qualifying children). A Puerto
Rico CTC filer must complete lines 4a, 4b
and 4c.
(11) Schedule 8812, Part I-A, line 5
(child tax credit). A Puerto Rico CTC filer
must complete line 5. In completing line
5, the Puerto Rico CTC filer must provide
the sum of the following:
(a) $3,600 multiplied by the number
entered on line 4b; and
(b) $3,000 multiplied by the number
entered on line 4c.
(12) Schedule 8812, Part I-A, line 6
(credit for other dependents) and line 7.
A Puerto Rico CTC filer must leave lines
6 and 7 blank.
(13) Schedule 8812, Part I-A, line 8. A
Puerto Rico CTC filer must enter on line 8
the amount entered on line 5.
(14) Schedule 8812, Part I-A, line 9: A
Puerto Rico CTC filer must enter on line 9
$200,000 (or $400,000 if married and fil-
ing a joint return).
(15) Schedule 8812, Part I-A, lines
10 and 11. A Puerto Rico CTC filer must
leave lines 10 and 11 blank.
(16) Schedule 8812, Part I-A, line 12.
A Puerto Rico CTC filer must enter on line
12 the amount entered on line 5.
(17) Schedule 8812, Part I-A, line 13.
A Puerto Rico CTC filer must check only
the box on line 13B.
(18) Schedule 8812, Part I-B, line 14a.
A Puerto Rico CTC filer must leave line
14a blank.
(19) Schedule 8812, Part I-B, line 14b.
A Puerto Rico CTC filer must enter on line
14b the amount entered on line 5.
(20) Schedule 8812, Part I-B, lines 14c
and 14d. A Puerto Rico CTC filer must
leave lines 14c and 14d blank.
(21) Schedule 8812, Part I-B, line 14e.
A Puerto Rico CTC filer must enter on line
14e the amount entered on line 5.
(22) Schedule 8812, Part I-B, line
14f (advance child tax credit payments
received). A Puerto Rico CTC filer must
enter on line 14f the aggregate amount
of advance child tax credit payments the
filer (and the filer’s spouse if filing joint-
ly) received for 2021, which may be ob-
tained from the filer’s Letter 6419 or the
filer’s IRS online account at https://www.
irs.gov/account and, as applicable, Letter
6419 of the filer’s spouse or the IRS on-
line account of the filer’s spouse.
(23) Schedule 8812, Part I-B, line 14g
(allowable child tax credit). A Puerto Rico
CTC filer must complete line 14g. To de-
termine this amount, the Puerto Rico CTC
filer must:
(a) Subtract the amount entered on line
14f from the amount entered on line 14e
(that is, the filer must subtract the aggre-
gate amount of advance child tax credit
payments that the filer received in 2021,
if any, from the amount of child tax credit
for which the filer is eligible); and
(b) Enter that result (that is, the allow-
able child tax credit) on line 14g.
(24) Schedule 8812, Part I-B, line 14h.
A Puerto Rico CTC filer must leave line
14h blank.
(25) Schedule 8812, Part I-B, line 14i
(refundable child tax credit). A Puerto
Rico CTC filer must enter on line 14i the
amount entered on line 14g.
(26) Schedule 8812, Parts I-C through
III, lines 15a through 50. A Puerto Rico
CTC filer must leave lines 15a through 50
blank.
.04 Simplified Return Is a Federal Tax
Return. A simplified return completed by a
Puerto Rico CTC filer in accordance with
the procedure described in section 5.03 of
this revenue procedure is a taxable year
2021 Federal tax return for all purposes,
whether filed on paper or electronically.
SECTION 6. APPLICABILITY
DATE
This revenue procedure applies to Fed-
eral tax returns filed after May 6, 2022.
SECTION 7. ADDITIONAL
INFORMATION
.01 Child Tax Credit and Advance
Child Tax Credit Payments. Individu-
als can obtain additional information

Bulletin No. 2022–21 1103 May 23, 2022
regarding advance child tax credit pay-
ments and the child tax credit for tax-
able year 2021 through the IRS child tax
credit and advance child tax credit pay-
ment webpage at https://www.irs.gov/
childtaxcredit2021.
.02 Completing a Federal Tax Re-
turn. Bona fide residents of Puerto Rico
can obtain additional information re-
garding how to complete their Federal
tax returns at https://www.irs.gov/Form-
1040PR (in Spanish); https://www.irs.
gov/Form1040SS; https://www.irs.gov/
Form1040SP (in Spanish); https://www.
irs.gov/Form1040; and https://www.irs.
gov/Form1040SR.
.03 Obtaining Tax Information in Oth-
er Languages. Taxpayers may obtain ba-
sic tax information in other languages at
https://www.irs.gov/MyLanguage.
SECTION 8. DRAFTING
INFORMATION
The principal author of this reve-
nue procedure is the Office of the As-
sociate Chief Counsel (Income Tax &
Accounting).

May 23, 2022 1104 Bulletin No. 2022–21
Part IV
Notice of Proposed
Rulemaking
Use of Actuarial Tables in
Valuing Annuities, Interests
for Life or a Term of
Years, and Remainder or
Reversionary Interests
REG-122770-18
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking.
SUMMARY: This document contains
proposed regulations relating to the use of
actuarial tables in valuing annuities, inter-
ests for life or a term of years, and remain-
der or reversionary interests. These reg-
ulations will affect the valuation of inter
vivos and testamentary transfers of inter-
ests dependent on one or more measuring
lives. These regulations are necessary be-
cause applicable law requires the actuari-
al tables to be updated to reflect the most
recent mortality experience available.
DATES: Written or electronic comments
and requests for a public hearing must be
received by July 5, 2022. Requests for a
public hearing must be submitted as pre-
scribed in the “Comments and Requests
for a Public Hearing” section.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic submis-
sions via the Federal eRulemaking Portal
at www.regulations.gov (indicate IRS and
REG-122770-18) by following the online
instructions for submitting comments.
Once submitted to the Federal eRulemak-
ing Portal, comments cannot be edited
or withdrawn. The IRS expects to have
limited personnel available to process
public comments that are submitted on
paper through mail. Until further notice,
any comments submitted on paper will
be considered to the extent practicable.
The Department of the Treasury (Trea-
sury Department) and the IRS will pub-
lish for public availability any comment
submitted electronically, and to the extent
practicable on paper, to its public docket.
Send paper submissions to: CC:PA:LP-
D:PR (REG-122770-18), room 5203,
Internal Revenue Service, PO Box 7604,
Ben Franklin Station, Washington, D.C.
20044.
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed regula-
tions, Mayer R. Samuels of the Office of
Associate Chief Counsel (Passthroughs
and Special Industries), (202) 317-6859;
concerning the submission of comments
or requests for a public hearing, Regina
L. Johnson, (202) 317-5177 (not toll-free
numbers).
SUPPLEMENTARY INFORMATION:
Background
This document contains amendments
to the Income Tax Regulations (26 CFR
part 1), the Estate Tax Regulations (26
CFR part 20), and the Gift Tax Regula-
tions (26 CFR part 25) to reflect revisions
to certain tables used for the valuation of
interests in property under section 7520 of
the Internal Revenue Code of 1986 (Code)
to reflect the most recent mortality experi-
ence available.
In General
Section 7520, effective for transfers
for which the valuation date is on or af-
ter May 1, 1989, generally 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 Secretary of
the Treasury or her delegate (Secretary)
by using an interest rate (rounded to the
nearest two-tenths of one percent) equal
to 120 percent of the Federal midterm rate
in effect under section 1274(d)(1) for the
month in which the valuation date falls. If
a charitable contribution is allowable for
any part of the property transferred, the
taxpayer may elect under section 7520(a)
to use such Federal midterm rate for either
of the two months preceding the month
in which the valuation date falls. Section
7520(c)(2), as it existed on May 1, 1989,
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 re-
vise these tables 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 proposed regulations contain
Table 2010CM that is based on data com-
piled from the 2010 census. For transfers
for which the valuation date is on or after
the applicability date of the Treasury de-
cision adopting these regulations as final
regulations (published as the final rule
in the Federal Register), the appropriate
actuarial factors based on Table 2010CM
may be computed by taxpayers. However,
for the convenience of taxpayers, actuarial
factors may be found on IRS websites and
publications referenced in these proposed
regulations. These proposed regulations
also make conforming amendments to
various sections of the existing regula-
tions to provide the references to these
revised actuarial factors. The updated ac-
tuarial tables will be available beginning
May 5, 2022, at no charge, electronical-
ly via the IRS website at https://www.irs.
gov/retirement-plans/actuarial-tables.
IRS Publications 1457 “Actuarial Valu-
ations Version 4A” (forthcoming 2022),
1458 “Actuarial Valuations Version 4B”
(forthcoming 2022), and 1459 “Actuari-
al Valuations Version 4C” (forthcoming
2022) will provide additional references
and explanations to the actuarial tables
that are published on the IRS website.
These publications will be available af-
ter the applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations. Table S (Single Life Re-
mainder Factors) and Table U(1) (Unitrust
Single Life Remainder Factors), which
are referenced and explained in Publica-
tions 1457 and 1458, respectively, will no
longer be published in these regulations.
Furthermore, the current Table S and Ta-
ble U(1), effective for transfers for which
the valuation date is after April 30, 2009,

Bulletin No. 2022–21 1105 May 23, 2022
and before the applicability date of the
Treasury decision adopting these regula-
tions as final regulations is published in
the Federal Register, will be moved to
sections containing actuarial material for
historical reference. Table B, Table D, Ta-
bles F(0.2) through F(20.0), Table J, and
Table K, which are not based on mortality
experience, are not changed.
The following chart summarizes the
applicable interest rates and the citations
to textual materials and tables for the var-
ious periods covered under the current
regulations. For purposes of this chart,
“DPAD” is the day prior to the applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations and
“AD” is the applicability date of the Trea-
sury decision adopting these regulations
as final regulations.
Cross Reference to Regulation Sections
Valuation Interest Regulation
Period Rate Section Table
Section 642:
Valuation, in general - 1.642(c)-6
before 01/01/52 4% 1.642(c)-6A(a)
01/01/52 - 12/31/70 3.5% 1.642(c)-6A(b)
01/01/71 - 11/30/83 6% 1.642(c)-6A(c)
12/01/83 - 04/30/89 10% 1.642(c)-6A(d) Table G
05/01/89 - 04/30/99 7520 1.642(c)-6A(e) Table S (5/1/89 - 4/30/99)
05/01/99 - 04/30/09 7520 1.642(c)-6A(f) Table S (5/1/99 - 4/30/09)
05/01/09 – DPAD 7520 1.642(c)-6A(g) Table S (5/1/09- DPAD)
on or after AD 7520 1.642(c)-6(e) Table S (on or after AD)
Section 664:
Valuation, in general - 1.664-4
before 01/01/52 4% 1.664-4A(a)
01/01/52 - 12/31/70 3.5% 1.664-4A(b)
01/01/71 - 11/30/83 6% 1.664-4A(c)
12/01/83 - 04/30/89 10% 1.664-4A(d) Table E, Table F(1)
05/01/89 - 04/30/99 7520 1.664-4A(e) Table U(1) (5/1/89 - 4/30/99)
05/01/99 - 04/30/09 7520 1.664-4A(f) Table U(1) (5/1/99 - 4/30/09)
05/01/09 - DPAD 7520 1.664-4A(g) Table U(1) (5/1/09-DPAD)
on or after AD 7520 1.664-4(e) Table U(1) (on or after AD), Table D, and Table F
See Pub. 1458, ver. 4A
Section 2031:
Valuation, in general - 20.2031-7
before 01/01/52 4% 20.2031-7A(a)
01/01/52 - 12/31/70 3.5% 20.2031-7A(b)
01/01/71 - 11/30/83 6% 20.2031-7A(c)
12/01/83 - 04/30/89 10% 20.2031-7A(d) Table A, Table B, Table LN
05/01/89 - 04/30/99 7520 20.2031-7A(e) Table S (5/1/89 - 4/30/99)
Table 80CNSMT
05/01/99 - 04/30/09 7520 20.2031-7A(f) Table S (5/1/99 - 4/30/09)
Table 90CM
05/01/09 - DPAD 7520 20.2031-7A(g) Table S (5/1/09 - DPAD)
Table 2000CM
on or after AD 7520 20.2031-7(d) Table S (on or after AD)
Table 2010CM
Table B, Table J, Table K
see Pub. 1457, ver. 4A

May 23, 2022 1106 Bulletin No. 2022–21
Section 2512:
Valuation, in general - 25.2512-5
before 01/01/52 4% 25.2512-5A(a)
01/01/52 - 12/31/70 3.5% 25.2512-5A(b)
01/01/71 - 11/30/83 6% 25.2512-5A(c)
12/01/83 - 04/30/89 10% 25.2512-5A(d)
05/01/89 - 04/30/99 7520 25.2512-5A(e)
05/01/99 - 04/30/09 7520 25.2512-5A(f)
05/01/09 - DPAD 7520 25.2512-5A(g)
on or after AD 7520 25.2512-5(d)
Applicability Dates
These regulations are proposed to be
applicable in the case of annuities, inter-
ests for life or a term of years, and re-
mainder or reversionary interests that are
valued as of a date on or after the first day
of the month following the date on which
the Treasury decision adopting these regu-
lations as final regulations is published in
the Federal Register.
Transitional Rules
The regulations provide certain rules
to facilitate the transition to the new ac-
tuarial tables. For gift tax purposes, if the
date of a transfer is on or after January 1,
2021, and before the applicability date of
the Treasury decision adopting these regu-
lations as final regulations, the donor may
choose to determine the value of the gift
(and/or any applicable charitable deduc-
tion) under tables based on either Table
2000CM or Table 2010CM. Similarly,
for estate tax purposes, if the decedent
dies on or after January 1, 2021, and be-
fore the applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations, the value of any interest
(and/or any applicable charitable deduc-
tion) may be determined in the discretion
of the decedent’s executor under tables
based on either Table 2000CM or Table
2010CM, provided that the decedent’s ex-
ecutor must use the same mortality table
to value all interests in the same property.
However, the section 7520 interest rate to
be utilized is the appropriate rate for the
month in which the valuation date occurs,
subject to the following special rule for
certain charitable transfers. Specifically,
in accordance with this transitional rule
and the rules contained in §§1.7520-2(a)
(2), 20.7520-2(a)(2), and 25.7520-2(a)
(2), in cases involving a charitable de-
duction, if the valuation date occurs on or
after January 1, 2021, but before the ap-
plicability date of the Treasury decision
adopting these regulations as final regu-
lations, and the executor or donor elects
under section 7520(a) to use the section
7520 interest rate for a month that is prior
to January 1, 2021, then the mortality ex-
perience contained in Table 2000CM must
be used. If the executor or donor uses the
section 7520 interest rate for a month that
is on or after January 1, 2021, but before
the applicability date of the Treasury de-
cision adopting these regulations as final
regulations, then the tables based on either
Table 2000CM or Table 2010CM may be
used. However, if the valuation date oc-
curs on or after the applicability date of
the Treasury decision adopting these regu-
lations as final regulations, the executor or
donor must use the new mortality experi-
ence contained in Table 2010CM even if
the use of a prior month’s interest rate is
elected under section 7520(a).
In addition, the regulations no longer
will provide that the estate of a decedent
who was under a mental disability that
prevented a change in the disposition of
the decedent’s property may elect to value
the property interest included in the gross
estate either under the mortality table and
interest rate in effect at the time the dece-
dent first became subject to the mental dis-
ability or under the mortality table and in-
terest rate in effect on the decedent’s date
of death. The taxpayer decedent, during
life and before the advent of the mental
disability, would not know, beforehand,
what the market interest rate would be at
his or her future date of death, but can rea-
sonably be expected to have understood
that the property interest would be valued
at the then-applicable market rate, what-
ever it might be. Becoming incapacitated
should not alter the effect of that under-
standing. Therefore, a special rule per-
mitting an election to use the interest rate
in effect at the time the decedent first be-
came subject to the mental disability is not
necessary. The same is true with respect
to mortality rates. Accordingly, estates of
decedents with a mental disability who die
after the applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations will be required to use the
mortality table and interest rate in effect
on the decedent’s date of death or the al-
ternate valuation date under section 2032,
if elected.
Special Analyses
These proposed regulations are not
subject to review under section 6(b) of
Executive Order 12866 pursuant to the
Memorandum of Agreement (April 11,
2018) between the Treasury Department
and the Office of Management and Bud-
get (OMB) regarding review of tax reg-
ulations. Therefore, a regulatory impact
assessment is not required.
Pursuant to the Regulatory Flexibili-
ty Act (5 U.S.C. chapter 6), it is hereby
certified that this proposed rule will not
have a significant economic impact on a
substantial number of small entities. This
document proposes to implement statuto-
rily required periodic updates to actuarial
tables used in valuing various interests in
property that are affected by a person’s
life expectancy. The updates would not
impose any direct compliance require-
ments on any entities other than the time
to read and understand the proposed up-
dates. Notwithstanding this certification,
the Treasury Department and the IRS in-
vite comment on the impact this proposed
rule would have on small entities.

Bulletin No. 2022–21 1107 May 23, 2022
The Treasury Department and the IRS
have assessed that the proposed regula-
tions do not establish a new collection
of information nor modify an existing
collection that requires the approval of
the Office of Management and Budget
under the Paperwork Reduction Act (44
U.S.C. chapter 35). The Treasury Depart-
ment and the IRS seek comments on this
assessment.
Pursuant to section 7805(f), this notice
of proposed rulemaking has been submit-
ted to the Chief Counsel for the Office of
Advocacy of the Small Business Adminis-
tration for comment on its impact on small
business.
Statement of Availability of IRS
Documents
IRS Revenue Procedures, Revenue
Rulings, Notices, and other guidance cit-
ed in this preamble are published in the
Internal Revenue Bulletin (or Cumulative
Bulletin) and are available from the Su-
perintendent of Documents, U.S. Govern-
ment Publishing Office, Washington, DC
20402, or by visiting the IRS website at
https://www.irs.gov.
Comments and Requests for Public
Hearing
The Treasury Department and the IRS
request comments on all aspects of the
proposed rules.
Before these proposed amendments to
the regulations are adopted as final reg-
ulations, consideration will be given to
comments that are submitted timely to the
IRS as prescribed in the preamble under
the ADDRESSES section. Any electron-
ic comments submitted, and to the extent
practicable any paper comments submit-
ted, will be made available at www.regu-
lations.gov or upon request.
A public hearing will be scheduled if
requested in writing by any person who
timely submits electronic or written com-
ments. Requests for a public hearing also
are encouraged to be made electronically.
If a public hearing is scheduled, notice of
the date and time for the public hearing
will be published in the Federal Register.
Announcement 2020-4, 2020-17 I.R.B 1,
provides that, until further notice, public
hearings conducted by the IRS will be
held telephonically. Any telephonic hear-
ing will be made accessible to people with
disabilities.
Drafting Information
The principal author of these regula-
tions is Mayer R. Samuels, Office of the
Associate Chief Counsel (Passthroughs
and Special Industries), IRS. However,
other personnel from the IRS and Trea-
sury Department participated in their
development.
List of Subjects
26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
26 CFR Part 20
Estate taxes, Reporting and record-
keeping requirements.
26 CFR Part 25
Gift taxes, Reporting and recordkeep-
ing requirements.
Proposed Amendments to the
Regulations
Accordingly, 26 CFR parts 1, 20, and
25 are proposed to be amended as follows:
PART 1--INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.170A-12 is amended
by:
1. Revising paragraphs (b)(2) and (3).
2. Adding paragraph (b)(4).
3. Revising paragraphs (e)(2) and (f)
The revisions and addition read as
follows:
§1.170A-12 Valuation of a remainder
interest in real property for contributions
made after July 31, 1969.
* * * * *
(b) * * *
(2) Computation of depreciation factor.
If the valuation of the remainder interest
in depreciable property is dependent upon
the continuation of one life, a special fac-
tor 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 inter-
est rate and life contingency rates from the
mortality table prescribed in §20.2031-7
of this chapter (or for periods before [ap
-
plicability date of the Treasury decision
adopting these regulations as final reg-
ulations], §20.2031-7A of this chapter)
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 on or after [ap-
plicability date of the Treasury decision
adopting these regulations as final regu-
lations], special factors for determining
the present value of a remainder interest
following one life may be computed by
taxpayers based on Table 2010CM, found
in §20.2031-7(d)(7)(ii) of this chapter,
and using the formula provided in this
paragraph (b)(2). Alternatively, taxpayers
may use the actuarial factors provided in
Table C to determine the special factor
for the remainder interest following one
life. Table C will be available beginning
May 5, 2022, at no charge, electronical-
ly 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). IRS Publication 1459,
“Actuarial Valuations Version 4C” (2022),
references and explains Table C and pro-
vides examples describing the compu-
tation. This publication will be available
after [date of publication of the final rule
in the Federal Register]. For transfers
for which the valuation date is on or af-
ter May 1, 2009, and before [applicabili-
ty date of the Treasury decision adopting
these regulations as final regulations],
special factors for determining the present
value of a remainder interest following
one life and an example describing the
computation are contained in the previ-
ous version of Table C, which is currently
available, at no charge, electronically via
the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. IRS
Publication 1459, “Actuarial Valuations
Version 3C” (2009), references and ex-
plains this version of Table C and provides

May 23, 2022 1108 Bulletin No. 2022–21
examples describing the computation.
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 remain-
der interest following one life, the special
factor may be obtained through use of the
formula in Figure 1 to this paragraph (b)
(2). The prescribed mortality table is Table
2010CM as set forth in §20.2031-7(d)(7)
(ii) of this chapter, or for periods before
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations], the appropriate table found
in §20.2031-7A of this chapter. Table
2010CM is referenced by IRS Publication
1459, “Actuarial Values Version 4C.” The
mortality tables prescribed for periods
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations] are referenced by prior
versions of IRS Publication 1459.
Figure 1 to paragraph (b)(2) – Formula for determining single life remainder interest in depreciable property

(3) Sample factors from actuarial Table S. The present value of a remainder interest
dependent on the termination of one life is determined by using the formula in §20.2031-
7(d)(2)(ii)(B) of this chapter to derive factors from the appropriate mortality table. For the
convenience of taxpayers, actuarial factors have been computed by IRS and appear in Table S.
The complete Table S can be found on the IRS website at
https://www.irs.gov/retirement-plans/actuarial-tables. For purposes of the example in paragraph
(b)(4) of this section, the following factors from Table S will be used:
Table 1 to paragraph (b)(3)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
Age Annuity Life Estate Remainder
62 14.6131 0.46762 0.53238

(4) Example. After [applicability date of the Treasury decision adopting these
regulations as final regulations], 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 28 years, at the end of which period the value of the house is expected to
be $10,000. The portion of the property considered to be depreciable is $90,000 (the value of the
house ($100,000) less its expected value at the end of 28 years ($10,000)). The portion of the
(3) Sample factors from actuarial Ta-
ble S. The present value of a remainder
interest dependent on the termination of
one life is determined by using the for-
mula in §20.2031-7(d)(2)(ii)(B) of this
chapter to derive factors from the appro-
priate mortality table. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table S.
The complete Table S can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables. For purposes
of the example in paragraph (b)(4) of this
section, the following factors from Table
S will be used:
Table 1 to paragraph (b)(3)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
AgeAnnuityLife EstateRemainder
6214.61310.467620.53238
(4) Example. After [applicability date of the
Treasury decision adopting these regulations as final
regulations], 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 28 years, at the end
of which period the value of the house is expected
to be $10,000. The portion of the property consid-
ered to be depreciable is $90,000 (the value of the
house ($100,000) less its expected value at the end
of 28 years ($10,000)). The portion of the proper-
ty considered to be nondepreciable is $40,000 (the
value of the land at the time of the gift ($30,000)
plus the expected value of the house at the end of 28
years ($10,000)). At the time of the gift, the inter-
est rate prescribed under section 7520 is 3.2 percent.
Based on an interest rate of 3.2 percent, the remain-
der factor for $1.00 prescribed in §20.2031-7(d) and
found in Table S for a person age 62 is 0.53238.
The value of the nondepreciable remainder interest
is $21,295.20 (0.53238 times $40,000). The factor
for the remainder interest in depreciable property is
computed under the formula described in paragraph
(b)(2) of this section and is 0.19392. (This factor,
0.19392, may instead be determined by using Table
C, which can be found on the IRS website at https://
www.irs.gov/retirement-plans/actuarial-tables, and
following the method provided in IRS Publication
1459, “Actuarial Values Version 4C”.) The value
of the depreciable remainder interest is $17,452.80
(0.19392 times $90,000). Therefore, the value of the
remainder interest is $38,748.00 ($21,295.20 plus
$17,452.80).
* * * * *

Bulletin No. 2022–21 1109 May 23, 2022
(e) * * *
(2) In the case of the valuation of a re-
mainder interest following two lives, the
special factor may be obtained through use
of the formula in Figure 2 to this paragraph
(e)(2). The prescribed mortality table is Table
2010CM as set forth in §20.2031-7(d)(7)(ii)
of this chapter, or for periods before [appli-
cability date of the Treasury decision adopt-
ing these regulations as final regulations],
the appropriate table found in §20.2031-7A
of this chapter. Table 2010CM is referenced
by IRS Publication 1459, “Actuarial Values
Version 4C.” The mortality tables prescribed
for periods before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations] are referenced by
prior versions of IRS Publication 1459.
Figure 2 to paragraph (e)(2)(i) – Formula for determining two-life remainder interest in depreciable property

* * * * *
(f) Applicability date. This section applies to contributions made after July 31, 1969,
except that paragraphs (b)(2), (3), and (4) and (e)(2) of this section apply to all contributions
made on or after [applicability date of the Treasury decision adopting these regulations as final
regulations].
Par. 3. Section 1.170A-14 is amended:
1. In paragraph (h)(4) by designating Example 1 through 12 as paragraphs (h)(4)(i)
through (xii), respectively.
2. By revising newly designated paragraph (h)(4)(ii).
3. In newly designated paragraphs (h)(4)(iii) and (iv) by removing “Example 2” and
adding “paragraph (h)(4)(ii) of this section (Example 2)” in its place.
4. In newly designated paragraph (h)(4)(v) by removing “Example 4” and adding
“paragraph (h)(4)(iv) of this section (Example 4)” in its place.
5. In newly designated paragraph (h)(4)(vi) by removing “Example 2” and adding
“paragraph (h)(2)(ii) of this section (Example 2)” in its place.
6. In newly designated paragraph (h)(4)(viii) by removing “Example 7” and adding
“paragraph (h)(4)(vii) of this section (Example 7)” in its place.
* * * * *
(f) Applicability date. This section ap-
plies to contributions made after July 31,
1969, except that paragraphs (b)(2), (3),
and (4) and (e)(2) of this section apply to
all contributions made on or after [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations].
Par. 3. Section 1.170A-14 is amended:
1. In paragraph (h)(4) by designating
Example 1 through 12 as paragraphs (h)
(4)(i) through (xii), respectively.
2. By revising newly designated para-
graph (h)(4)(ii).
3. In newly designated paragraphs (h)
(4)(iii) and (iv) by removing “Example 2”
and adding “paragraph (h)(4)(ii) of this
section (Example 2)” in its place.
4. In newly designated paragraph (h)
(4)(v) by removing “Example 4” and add-
ing “paragraph (h)(4)(iv) of this section
(Example 4)” in its place.
5. In newly designated paragraph (h)(4)
(vi) by removing “Example 2” and adding
“paragraph (h)(2)(ii) of this section (Ex-
ample 2)” in its place.
6. In newly designated paragraph (h)
(4)(viii) by removing “Example 7” and
adding “paragraph (h)(4)(vii) of this sec-
tion (Example 7)” in its place.
7. In newly designated paragraph (h)
(4)(xi) by removing “example (10)” and
adding “paragraph (h)(4)(x) of this section
(Example 10)” in its place.
8. By revising paragraph (j).
The revisions read as follows:
§1.170A-14 Qualified conservation
contributions.
* * * * *
(h) * * *
(4) * * *
(ii) Example 2. In 1984 B, who is 62, donates a
remainder interest in Greenacre to a qualifying or-
ganization for conservation purposes. Greenacre is
a tract of 200 acres of undeveloped woodland that is
valued at $200,000 at its highest and best use. Under
§1.170A-12(b), the value of a remainder interest in
real property following one life is determined under
§25.2512-5 of this chapter (Gift Tax Regulations).
(See §25.2512-5A of this chapter with respect to the
valuation of annuities, interests for life or a term of
years, and remainder or reversionary interests trans-
ferred before [applicability date of the Treasury deci-
sion adopting these regulations as final regulations].)
For transfers occurring after November 30, 1983, and
before May 1, 1989, the single life remainder fac-
tors, valued at 10 percent, can be found in Table A of
§20.2031-7A(d)(6) of this chapter. Accordingly, the
value of the remainder interest, and thus the amount
eligible for an income tax deduction under section
170(f), is $55,996 ($200,000 × 0.27998).
* * * * *
(j) Applicability dates. Except as other-
wise provided in paragraph (g)(4)(ii) and
paragraph (i) of this section, this section
applies only to contributions made on or
after December 18, 1980. Paragraph (h)
(4)(ii) of this section applies on and after
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations].
Par. 4. Section 1.642(c)-6 is amended
by:
1. Revising paragraph (d).
2. Redesignating paragraph (e) as para-
graph (g) of §1.642(c)-6A.
3. Adding new paragraph (e) and revis-
ing paragraph (f).
The revisions and addition read as
follows:
§1.642(c)-6 Valuation of a remainder
interest in property transferred to a
pooled income fund.
* * * * *

May 23, 2022 1110 Bulletin No. 2022–21
(d) Valuation. The present value of
the remainder interest in property trans-
ferred to a pooled income fund on or after
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations], is determined under para-
graph (e) of this section. The present value
of the remainder interest in property trans-
ferred to a pooled income fund for which
the valuation date is before [applicability
date of the Treasury decision adopting
these regulations as final regulations] is
determined under the following sections:
Table 6 to paragraph (d)
Valuation DatesApplicable Regulations
AfterBefore
-01-01-521.642(c)-6A(a)
12-31-5101-01-711.642(c)-6A(b)
12-31-7012-01-831.642(c)-6A(c)
11-30-8305-01-891.642(c)-6A(d)
04-30-8905-01-991.642(c)-6A(e)
04-30-9905-01-091.642(c)-6A(f)
04-30-09AD1.642(c)-6A(g)
AD = [applicability date of the Treasury decision adopting these regulations as final regulations].
(e) Present value of the remainder in-
terest in the case of transfers to pooled
income funds for which the valuation
date is on or after [applicability date
of the Treasury decision adopting these
regulations as final regulations]--(1) In
general. In the case of transfers to pooled
income funds for which the valuation
date is on or after [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations], the present
value of a remainder interest is deter-
mined 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 individ-
ual is computed by using the formula in
§20.2031-7(d)(2)(ii)(B) of this chapter
to derive factors from the appropriate
mortality table. For the convenience of
taxpayers, actuarial factors have been
computed by IRS and appear in Table S.
Table S will be available beginning May
5, 2022, at no charge, electronically via
the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables (or a
corresponding URL as may be updat-
ed from time to time). Table S is refer-
enced and explained by IRS Publica-
tion 1457 “Actuarial Valuations Version
4A,” which will be available after [date
of publication of the final rule in the
Federal Register]. For purposes of the
computations under this section, the age
of an individual is the age at the individ-
ual’s nearest birthday.
(2) Transitional rule for valuation of
transfers to pooled income funds. For pur-
poses of section 170, 2055, 2106, 2522, or
2624, in the case of transfers to a pooled
income fund for which the valuation date
is on or after January 1, 2021, and before
[applicability date of the Treasury decision
adopting these regulations as final regula-
tions], the present value of the remainder
interest under this section is determined
by using the section 7520 interest rate for
the month in which the valuation date oc-
curs (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. For the con-
venience of taxpayers, actuarial factors
based on Table 2010CM appear in the
proposed version of Table S, and actuarial
factors based on Table 2000CM appear in
the current version of Table S, which will
be available beginning May 5, 2022, 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 consis-
tently use the same mortality basis with
respect to each interest (income, remain-
der, partial, etc.) in the same property, and
with respect to all transfers occurring on
the valuation date. For example, gift and
income tax charitable deductions with
respect to the same transfer must be de-
termined based on factors with the same
mortality basis, and all assets includible
in the gross estate and/or estate tax de-
ductions claimed must be valued based on
factors with the same mortality basis.
(3) Present value of a remainder inter-
est. The present value of a remainder in-
terest in property transferred to a pooled
income fund is computed on the basis of--
(i) Life contingencies determined from
the values of l
x
that are set forth in Table
2010CM in §20.2031-7(d)(7)(ii) of this
chapter (see §20.2031-7A of this chapter
for certain prior periods); and
(ii) Discount at a rate of interest, com-
pounded annually, equal to the highest
yearly rate of return of the pooled income
fund for the three taxable years immedi-
ately 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 paragraph (c) of this section 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 para-
graph (e)(3)(ii), the first taxable year of a

Bulletin No. 2022–21 1111 May 23, 2022
pooled income fund is considered a tax-
able year even though the taxable year
consists of less than 12 months. Howev-
er, 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 three taxable years immediately pre-
ceding the taxable year in which the trans-
fer of property is made has been purposely
manipulated to be substantially less than
the rate of return that otherwise would be
reasonably anticipated with the purpose of
obtaining an excessive charitable deduc-
tion, that rate of return may not be used.
In that case, the highest yearly rate of re-
turn of the fund is determined by treating
the fund as a pooled income fund that has
been in existence for less than three pre-
ceding taxable years.
(4) Pooled income funds in existence
less than three taxable years. If a pooled
income fund has been in existence less than
three taxable years immediately preceding
the taxable year in which the transfer is
made to the fund and the transfer to the
fund is made on or after May 1, 1989, the
highest rate of return is deemed to be the
interest rate (rounded to the nearest two-
tenths of one percent) that is one percent
less than the highest annual average of the
monthly section 7520 rates for the three
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 calen-
dar year using the monthly section 7520
rates for the three year period immediately
preceding the calendar year in which each
transfer to the fund is made until the fund
has been in existence for three taxable
years and can compute its highest rate of
return for the three taxable years immedi-
ately 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--(i) Factor. The factor that is used
in determining the present value of a re-
mainder interest that is dependent on the
termination of the life of one individual
is the factor obtained through use of the
formula in §20.2031-7(d)(2)(ii)(B) of this
chapter to derive factors from the appro-
priate mortality table. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table S.
Table S will be available beginning May
5, 2022, at no charge, electronically via
the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. Table S
is referenced and explained in IRS Publi-
cation 1457 “Actuarial Valuations Version
4A,” which will be available after [date of
publication of the final rule in the Federal
Register]. In using the section of Table S
for the interest rate equal to the appropri-
ate yearly rate of return, the appropriate
remainder factor is opposite the number
that corresponds to the age of the individ-
ual upon whose life the value of the re-
mainder interest is based (See §1.642(c)-
6A for certain prior periods). The tables
referenced by IRS Publication 1457 “Ac-
tuarial Valuations Version 4A” include
factors for yearly rates of return from 0.2
to 20 percent, inclusive, in increments of
two-tenths of one percent. For other situ-
ations, see paragraph (b) of this section.
If the yearly rate of return is a percentage
that is between the yearly rates of return
for which factors are provided by Table S,
an exact method of obtaining the applica-
ble factors (such as through software us-
ing the actual rate of return and the actuar-
ial formulas provided in §20.2031-7(d)(2)
(ii)(B) of this chapter) or a linear interpo-
lation must be used, provided whichever
method used is applied consistently. 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.
(ii) Sample factors from actuarial Ta-
ble S. For purposes of the example in para-
graph (e)(5)(iii) of this section, the follow-
ing factors from Table S will be used:
Table 7 to paragraph (e)(5)(ii)
Factors from Table S - Based on Table 2010CM
Interest at 5.4 Percent
AgeAnnuityLife EstateRemainder
5513.25150.715580.28442
Interest at 5.6 Percent
AgeAnnuityLife EstateRemainder
5512.97100.726370.27363
(iii) Example of interpolation. After [applicabili-
ty date of the Treasury decision adopting these regu-
lations as final regulations], A, whose age is 54 years
and 8 months, transfers $100,000 to a pooled income
fund, and retains a life income interest in the prop-
erty. The highest yearly rate of return earned by the
fund for its 3 preceding taxable years is 5.43 percent.
In Table S, the remainder factor opposite 55 years
under 5.4 percent is 0.28442 and under 5.6 percent is
0.27363. The present value of the remainder interest
is $28,280, computed as illustrated in Figure 1 to this
paragraph (e)(5)(iii).

May 23, 2022 1112 Bulletin No. 2022–21
Figure 1 to paragraph (e)(5)(iii) – Illustration of interpolation method

(6) Actuarial tables. In the case of transfers for which the valuation date is on or after
[applicability date of the Treasury decision adopting these regulations as final regulations], 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 using the formula in §20.2031-7(d)(2)(ii)(B)
of this chapter to derive factors from the appropriate mortality table. For the convenience of
taxpayers, actuarial factors have been computed by IRS and appear in Table S. Table S will be
available beginning May 5, 2022, at no charge, electronically via the IRS website at
https://www.irs.gov/retirement-plans/actuarial-tables. Table S is referenced and explained in
IRS Publication 1457 "Actuarial Valuations Version 4A,” which will be available after [date of
publication of the final rule in the Federal Register].
(f) Applicability date. This section applies on and after [applicability date of the
Treasury decision adopting these regulations as final regulations].
Par. 5. The undesignated center heading immediately preceding §1.642(c)-6A is revised
to read as follows:
(6) Actuarial tables. In the case of
transfers for which the valuation date is
on or after [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], the present value of a
remainder interest dependent on the termi-
nation of one life in the case of a transfer to
a pooled income fund is determined by us-
ing the formula in §20.2031-7(d)(2)(ii)(B)
of this chapter to derive factors from the
appropriate mortality table. For the conve-
nience of taxpayers, actuarial factors have
been computed by IRS and appear in Ta-
ble S. Table S will be available beginning
May 5, 2022, at no charge, electronically
via the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. Table S
is referenced and explained in IRS Publi-
cation 1457 “Actuarial Valuations Version
4A,” which will be available after [date of
publication of the final rule in the Federal
Register].
(f) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 5. The undesignated center head-
ing immediately preceding §1.642(c)-6A
is revised to read as follows:
Pooled Income Fund Actuarial Tables
Applicable Before [Applicability Date of
the Treasury Decision Adopting These
Regulations as Final Regulations]
Par. 6. Section 1.642(c)-6A is amended
by:
1. Revising the section heading.
2. In newly redesignated paragraph (g):
i. The heading and paragraphs (g)(1)
through (5) and (g)(6) introductory text
are revised.
ii. Paragraph (g)(7) is added.
The revisions and addition read as
follows:
§1.642(c)-6A Valuation of charitable
remainder interests for which the
valuation date is before [applicability
date of the Treasury decision adopting
these regulations as final regulations].
* * * * *
(g) Present value of the remainder in-
terest in the case of transfers to pooled
income funds for which the valuation date
is on or after May 1, 2009, and before [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions]--(1) In general. In the case of trans-
fers to pooled income funds for which the
valuation date is on or after May 1, 2009,
and before [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], 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 pre-
scribed tables under certain circumstanc-
es). The present value of a remainder in-
terest that is dependent on the termination
of the life of one individual is computed
by the use of Table S in paragraph (g)(6)
of this section. For purposes of the com-
putations 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

Bulletin No. 2022–21 1113 May 23, 2022
purposes of section 2055, 2106, or 2624, if
on May 1, 2009, the decedent was under a
mental disability so that the disposition of
the property could not be changed, and the
decedent died on or after May 1, 2009, but
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations] without having regained
the ability to dispose of the decedent’s
property, or if the decedent died within 90
days of the date that the decedent first re-
gained that ability on or after May 1, 2009,
but before [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], the present value of
a remainder interest is determined as if the
valuation date with respect to the dece-
dent’s gross estate is either before May 1,
2009, or after April 30, 2009, at the option
of the decedent’s executor.
(ii) For purposes of section 170, 2055,
2106, 2522, or 2624, in the case of trans-
fers to a pooled income fund for which
the valuation date is on or after May 1,
2009, and before July 1, 2009, the present
value of the remainder interest under this
section is determined 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 appropri-
ate actuarial tables under either paragraph
(f)(6) or (g)(6) of this section, at the option
of the donor or the decedent’s executor, as
the case may be.
(iii) For purposes of paragraphs (g)(2)
(i) and (ii) of this section, where the donor
or decedent’s executor is given the option
to use the appropriate actuarial tables un-
der either paragraph (f)(6) or (g)(6) of this
section, the donor or decedent’s executor
must consistently use the same mortality
basis with respect to each interest (in-
come, remainder, partial, etc.) in the same
property, and with respect to all transfers
occurring on the valuation date. For ex-
ample, gift and income tax charitable de-
ductions with respect to the same transfer
must be determined based on factors with
the same mortality basis, and all assets in-
cludible in the gross estate and/or estate
tax deductions claimed must be valued
based on factors with the same mortality
basis.
(3) Present value of a remainder inter-
est. The present value of a remainder in-
terest in property transferred to a pooled
income fund is computed on the basis of --
(i) Life contingencies determined from
the values of l
x
that are set forth in Table
2000CM in §20.2031-7A(g)(4) of this
chapter; and
(ii) Discount at a rate of interest, com-
pounded annually, equal to the highest
yearly rate of return of the pooled income
fund for the three taxable years immedi-
ately 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)-6(e)(3)(ii) apply for the deter-
mining the yearly rate of return.
(4) Pooled income funds in existence
less than three taxable years. The provi-
sions of §1.642(c)-6(e)(4) apply for de-
termining the highest yearly rate of return
when the pooled income fund has been in
existence less than three taxable years.
(5) Computation of value of remainder
interest. The factor that is used in deter-
mining the present value of a remainder
interest that is dependent on the termina-
tion of the life of one individual is the fac-
tor from Table S in paragraph (g)(6) of this
section under the appropriate yearly rate
of return opposite the number that corre-
sponds to the age of the individual upon
whose life the value of the remainder in-
terest is based. Table S in paragraph (g)(6)
of this section includes factors for year-
ly rates of return from 0.2 to 14 percent,
inclusive, in increments of two-tenths of
one percent. Actuarial factors that do not
appear in paragraph (g)(6) of this sec-
tion may be computed directly by using
the formula in §20.2031-7(d)(2)(ii)(B)
of this chapter to derive factors from the
appropriate mortality table. For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear in
Table S that is referenced and explained
by IRS Publication 1457, “Actuarial Val-
uations Version 3A” (2009). The table 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). 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 by Table S, an exact method of
obtaining the applicable factors (such as
through software using the actual rate of
return and actuarial formulas provided in
§20.2031-7(d)(2)(ii)(B) of this chapter) or
a linear interpolation must be used, pro-
vided whichever method used is applied
consistently. The present value of the re-
mainder interest is determined by multi-
plying the fair market value of the proper-
ty on the valuation date by the appropriate
remainder factor. For an example of a
computation of the present value of a re-
mainder interest requiring a linear interpo-
lation adjustment, see §1.642(c)-6(e)(5).
(6) Actuarial tables. In the case of
transfers for which the valuation date is on
or after May 1, 2009, and before [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations],
and without regard to the headings in the
tables in this paragraph (g)(6) that do not
contain this termination date for the appli-
cability of the tables, the present value of a
remainder interest dependent on the termi-
nation of one life in the case of a transfer
to a pooled income fund is determined by
using the following tables:
* * * * *
(7) Applicability dates. Paragraphs (g)
(1) through (6) of this section apply on and
after May 1, 2009, and before [applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations].
Par. 7. Section 1.664-2 is amended by
revising paragraphs (c) and (e) as follows:
§1.664-2 Charitable remainder annuity
trust.
* * * * *
(c) Calculation of the fair market value
of the remainder interest of a charitable
remainder annuity trust. For purposes of
sections 170, 2055, 2106, and 2522, the
fair market value of the remainder inter-
est of a charitable remainder annuity trust
(as described in this section) is the net fair
market value (as of the appropriate valu-
ation date) of the property placed in trust
less the present value of the annuity. For
purposes of this section, valuation date
means, in general, the date on which the
property is transferred to the trust by the
donor regardless of when the trust is cre-
ated. In the case of transfers to a charita-
ble remainder annuity trust for which the
valuation date is after April 30, 1999, if an
election is made under section 7520 and

May 23, 2022 1114 Bulletin No. 2022–21
§1.7520-2(b) to compute the present val-
ue of the charitable interest by using the
interest rate component for either of the 2
months preceding the month in which the
transfer is made, the month so elected is
the valuation date for purposes of deter-
mining the interest rate and mortality ta-
bles. For purposes of section 2055 or 2106,
the valuation date is the date of death un-
less the alternate valuation date is elected
in accordance with section 2032 in which
event, and within the limitations set forth
in section 2032 and the regulations in this
part under section 2032, the valuation date
is the alternate valuation date. If the dece-
dent’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 valu-
ation date, the month so elected is the val-
uation date for purposes of determining
the interest rate and mortality tables. The
present value of an annuity is computed
under §20.2031-7(d) of this chapter for
transfers for which the valuation date is on
or after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], or under §20.2031-7A(a)
through (g) of this chapter, whichever is
applicable, for transfers for which the val-
uation date is before [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations]. See, howev-
er, §1.7520-3(b) (relating to exceptions to
the use of prescribed tables under certain
circumstances).
* * * * *
(e) Applicability date. Paragraph (c) of
this section applies on and after [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations].
Par. 8. Section 1.664-4 is amended by:
1. Revising paragraphs (a)(1) and (d).
2. In paragraph (e):
i. Redesignating the paragraph head-
ing as the heading for §1.664-4A(g)
and paragraphs (e)(1), (2), (5), and (7)
as §1.664-4A(g)(1), (2), (5), and (6),
respectively.
ii. Adding a new paragraph heading
and new paragraphs (e)(1), (2), and (5).
iii. Revising the heading for paragraph
(e)(6).
iv. Redesignating the text of paragraph
(e)(6) as paragraph (e)(6)(iii).
v. Adding paragraphs (e)(6)(i) and (ii).
vi. Revising the introductory text of
newly redesignated paragraph (e)(6)(iii),
preceding Table D.
vii. Adding a new paragraph (e)(7).
3. Revising paragraph (f).
The additions and revisions read as
follows:
§1.664-4 Calculation of the fair market
value of the remainder interest in a
charitable remainder unitrust.
(a) * * *
(1) Life contingencies determined as to
each life involved, from the values of l
x
set
forth in Table 2010CM in §20.2031-7(d)
(7)(ii) of this chapter in the case of trans-
fers for which the valuation date is on or
after [applicability date of the Treasury de-
cision adopting these regulations as final
regulations]; or from Table 2000CM con-
tained in §20.2031-7A(g)(4) of this chap-
ter in the case of transfers for which the
valuation date is on or after May 1, 2009,
and before [applicability date of the Trea-
sury decision adopting these regulations
as final regulations]. See §20.2031-7A(a)
through (f) of this chapter, whichever is
applicable, for transfers for which the val-
uation date is before May 1, 2009;
* * * * *
(d) Valuation. The fair market val-
ue of a remainder interest in a charita-
ble remainder unitrust (as described in
§1.664-3) for transfers for which the val-
uation date is on or after [applicability
date of the Treasury decision adopting
these regulations as final regulations], is
its present value determined under para-
graph (e) of this section. The fair market
value of a remainder interest in a chari-
table remainder unitrust (as described in
§1.664-3) for transfers for which the val-
uation date is before [applicability date
of the Treasury decision adopting these
regulations as final regulations], is its
present value determined under the fol-
lowing sections:
Table 1 to paragraph (d)
Valuation DatesApplicable Regulations
AfterBefore
-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)
04-30-09AD1.664-4A(g)
AD = [applicability date of the Treasury decision adopting these regulations as final regulations].
(e) Valuation of charitable remainder
unitrusts having certain payout sequenc-
es for transfers for which the valuation
date is on or after [applicability date of
the Treasury decision adopting these
regulations as final regulations]--(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 [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], the present value

Bulletin No. 2022–21 1115 May 23, 2022
of a remainder interest is determined un-
der paragraphs (e)(3) through (7) of this
section, provided that, in a short taxable
year, the trustee shall 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 ta-
bles under certain circumstances).
(2) Transitional rule for valuation of
charitable remainder unitrusts. For pur-
poses of section 170, 2055, 2106, 2522,
or 2624, in the case of transfers to a
charitable remainder unitrust for which
the valuation date is on or after January
1, 2021, and before [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations], the present
value of a remainder interest based on one
or more measuring lives is determined un-
der 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 select-
ed 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. For the convenience of taxpayers, ac-
tuarial factors based on Table 2010CM
appear in the proposed version of Table
U(1), and actuarial factors based on Table
2000CM appear in the current version of
Table U(1), which will be available begin-
ning May 5, 2022, at no charge, electron-
ically via the IRS website at https://www.
irs.gov/retirement-plans/actuarial-tables
(or a corresponding URL as may be up-
dated 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 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.
* * * * *
(5) Period is the life of one individu-
al--(i) Factor. If the period described in
§1.664-3(a)(5) is the life of one individ-
ual, 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 [insert the applicability date
of the Treasury decision adopting these
regulations as final regulations] is the
factor obtained through the use of the for-
mula in Figure 1 to this paragraph (e)(5)
(i). The prescribed mortality table is Ta-
ble 2010CM as set forth in §20.2031-7(d)
(7)(ii) of this chapter, or for periods be-
fore [applicability date of the Treasury
decision adopting these regulations as
final regulations], the appropriate table
found in §20.2031-7A of this chapter. Ta-
ble 2010CM is referenced by IRS Publi-
cation 1458, “Actuarial Values Version
4B.” The mortality tables prescribed for
periods before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations] 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) will be available beginning May 5,
2022, at no charge, electronically via the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables (or a corre-
sponding URL as may be updated from
time to time). Table U(1) is referenced and
explained by IRS Publication 1458 “Actu-
arial Valuations Version 4B,” which will
be available after [date of publication of
the final rule in the Federal Register]. For
purposes of the computations described in
this paragraph (e)(5), the age of an indi-
vidual is the age of that individual at the
individual’s nearest birthday. If the adjust-
ed 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 factors
(such as through software using the actu-
al adjusted payout rate and the actuarial
formula in this paragraph (e)(5)) or a lin-
ear interpolation must be used, provided
whichever method used is applied consis-
tently. 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 Val-
uations Version 4B”. Alternatively, the
Commissioner may supply a factor upon
a request for a ruling. See paragraph (b)
of this section.

May 23, 2022 1116 Bulletin No. 2022–21
Figure 1 to paragraph (e)(5)(i) – Formula for determining unitrust remainder factors
(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 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. 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

(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
(ii) Sample factors from actuarial Ta-
ble 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
Age4.8%5.0%5.2%
770.61491 0.60343 0.59223
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 [applicabili-
ty date of the Treasury decision adopting these regu-
lations as final regulations], A, whose age is 76 years
and 11 months, transfers $100,000 to a charitable re-
mainder 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 fac-
tor is 0.976683 for semiannual payments payable
at the end of the semiannual period. The adjusted
payout rate is 4.8834% (5% × 0.976683). Based on
interpolating between the remainder factors in Table
U(1), the present value of the remainder interest is
$61,012, computed as illustrated in Figure 2 to this
paragraph (e)(5)(iii).

Bulletin No. 2022–21 1117 May 23, 2022
Figure 2 to paragraph (e)(5)(iii) – Illustration of unitrust interpolation method

(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). For the convenience of taxpayers,
actuarial factors have been computed by 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 after [date of
publication of the final rule in the Federal Register]. 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 [applicability date
of the Treasury decision adopting these regulations as final regulations], where the present value
of a charitable remainder unitrust interest is dependent on the termination of a life interest, see
(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 trans-
fers 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 de-
termined by using the formula in Figure
3 to this paragraph (e)(6)(i). For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear
in Table D. Table D can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables (or a corre-
sponding URL as may be updated from
time to time). Table D is referenced and
explained in IRS Publication 1458 “Actu-
arial Valuations Version 4B,” which will
be available after [date of publication of
the final rule in the Federal Register].
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 [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], 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 sec-
tion. See, however, §1.7520-3(b) (relating
to exceptions to the use of prescribed ta-
bles under certain circumstances).
Figure 3 to paragraph (e)(6)(i) – Formula for determining term certain unitrust remainder factors
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

(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). For the convenience of taxpayers, actuarial
factors have been computed by 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 after [date of
publication of the final rule in the Federal Register]. 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

May 23, 2022 1118 Bulletin No. 2022–21
(ii) Unitrust payout rate adjustment
factors. For transfers for which the valu-
ation 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). For
the convenience of taxpayers, actuari-
al factors have been computed by 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). Ta-
bles F(0.2) through F(20.0) are referenced
and explained in IRS Publication 1458
“Actuarial Valuations Version 4B,” which
will be available after [date of publication
of the final rule in the Federal Register].
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 per-
cent, inclusive.
Figure 4 to paragraph (e)(6)(ii) – Formula for determining unitrust payout rate adjustment factors

(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:
* * * * *
(7) Actuarial Table U(1) for transfers for which the valuation date is on or after
[applicability date of the Treasury decision adopting these regulations as final regulations]. 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 factors from the appropriate mortality table. For the convenience of taxpayers,
actuarial factors have been computed by IRS and appear in Table U(1). For transfers for which
the valuation date is on or after [applicability date of the Treasury decision adopting these
regulations as final regulations], the actuarial tables will be available beginning May 5, 2022, 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" (2022). This publication will be available after [date of publication of
the final rule in the Federal Register]. 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 [applicability date of the
(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:
* * * * *
(7) Actuarial Table U(1) for transfers
for which the valuation date is on or af-
ter [applicability date of the Treasury
decision adopting these regulations as
final regulations]. The present value of a
remainder interest in a charitable remain-
der unitrust that is dependent on the ter-
mination 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 de-
rive factors from the appropriate mortality
table. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table U(1). For trans-
fers for which the valuation date is on or
after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], the actuarial tables will
be available beginning May 5, 2022, 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 Pub-
lication 1458, “Actuarial Valuations Ver-
sion 4B” (2022). This publication will be
available after [date of publication of the
final rule in the Federal Register]. See,
however, §1.7520-3(b) (relating to excep-
tions to the use of prescribed tables under
certain circumstances).
(f) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 9. The undesignated center head-
ing immediately preceding §1.664-4A is
revised to read as follows:
Unitrust Actuarial Tables Applicable
Before [Applicability Date of the Treasury
Decision Adopting These Regulations as
Final Regulations]
Par. 10. Section 1.664-4A is amended
by:
1. Revising the section heading.
2. In newly redesignated paragraph (g):
i. Revising the heading and paragraphs
(g)(1) and (2).
ii. Adding paragraphs (g)(3) and (4).
iii. Revising paragraph (g)(5).
iv. In paragraph (g)(6), revising the in-
troductory text.
v. Adding paragraph (g)(7).
The additions and revisions read as
follows:
§1.664-4A Valuation of charitable
remainder interests for which the
valuation date is before [applicability
date of the Treasury decision adopting
these regulations as final regulations].
* * * * *
(g) Valuation of charitable remainder
unitrusts having certain payout sequences
for transfers for which the valuation date
is on or after May 1, 2009, and before [ap-
plicability date of the Treasury decision
adopting these regulations as final regu-
lations]--(1) In general. Except as other-
wise provided in paragraph (g)(2) of this
section, in the case of transfers for which
the valuation date is on or after May 1,

Bulletin No. 2022–21 1119 May 23, 2022
2009, and before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations], the present val-
ue of a remainder interest is determined
under paragraphs (g)(3) through (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 dis-
tribute 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, 2009, the decedent was un-
der a mental disability so that the disposi-
tion of the property could not be changed,
and the decedent died on or after May 1,
2009, but before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations], without hav-
ing regained the ability to dispose of the
decedent’s property, or if the decedent
died within 90 days of the date that the
decedent first regained that ability on or
after May 1, 2009, but before [applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations], the
present value of a remainder interest un-
der this section is determined as if the val-
uation date with respect to the decedent’s
gross estate is either before May 1, 2009,
or after April 30, 2009, at the option of the
decedent’s executor.
(ii) For purposes of sections 170, 2055,
2106, 2522, or 2624, in the case of trans-
fers to a charitable remainder unitrust for
which the valuation date is on or after May
1, 2009, and before July 1, 2009, the pres-
ent 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 appropri-
ate actuarial tables under either paragraph
(f)(6) or (g)(6) of this section, at the option
of the donor or the decedent’s executor, as
the case may be.
(iii) For purposes of paragraphs (g)(2)
(i) and (ii) of this section, where the do-
nor or decedent’s executor is given the
option to use the appropriate actuarial
tables under either paragraph (f)(6) or
(g)(6) of this section, the donor or dece-
dent’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 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. The adjusted
payout rate is determined by applying the
formula in §1.664-4(e)(6)(ii) for the sec-
tion 7520 interest rate applicable to the
transfer to derive a factor. For the conve-
nience of taxpayers, actuarial factors have
been computed by IRS, for interest rates
from 0.2 to 20 percent, inclusive, and ap-
pear in Tables F(0.2) through F(20.0). Ta-
bles 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 Valua-
tions Version 3B.” The payout adjustment
factors from Table F can also be found in
§1.664-4(e)(6)(iii), but only for interest
rates from 4.2 to 14 percent, inclusive. Al-
ternatively, the Commissioner may supply
a factor upon a request for a ruling. See
§1.664-4(b). See §1.664-4(e) for rules ap-
plicable in determining the adjusted pay-
out rate.
(4) Period is a term of years. If the pe-
riod described in §1.664-3(a)(5) is a term
of years, the factor that is used in deter-
mining the present value of the remainder
interest is determined by applying the for-
mula in §1.664-4(e)(6)(i) under the appro-
priate adjusted payout rate corresponding
to the number of years in the term. For
the convenience of taxpayers, actuarial
factors have been computed by 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 3B.” The
remainder factors from Table D also can
be found in §1.664-4(e)(6)(iii), but only
for adjusted payout rates from 4.2 to 14
percent, inclusive. If the adjusted payout
rate is a percentage that is between the
adjusted payout rate for which factors are
provided by Table D, an exact method of
obtaining the applicable factors (such as
through software using the actual rate of
return and the actuarial formula provided
in §1.664-4(e)(6)(i)) or a linear interpo-
lation must be used, provided whichever
method used is applied consistently. The
present value of the remainder interest
is determined by multiplying the net fair
market value (as of the appropriate valua-
tion date) of the property placed in trust by
the factor determined under this paragraph
(g)(4). Generally, for purposes of this sec-
tion, 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, and, in the case of a testamen-
tary transfer under sections 2055, 2106,
or 2624, the valuation date is the date of
death. See §1.664-4(e)(4) for additional
rules regarding the valuation date, and for
an example that illustrates the application
of this paragraph (g)(4).
(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 on or after
May 1, 2009, and before [applicability
date of the Treasury decision adopting
these regulations as final regulations],
may be computed directly by using the
formula in §1.664-4(e)(5)(i) to derive
factors from the appropriate mortality
table. For the convenience of taxpayers,
actuarial factors have been computed
by IRS and appear in Table U(1). Table
U(1) can be found on the IRS website at
https://www.irs.gov/retirement-plans/ac-
tuarial-tables (or a corresponding URL
as may be updated from time to time).
Table U(1) is referenced and explained
in IRS Publication 1458 “Actuarial Val-
uations Version 3B.” The remainder fac-
tors from Table U(1) also can be found in
paragraph (g)(6) of this section, but only
for adjusted payout rates from 4.2 to 14
percent, inclusive. For purposes of the
computations described in this paragraph
(g)(5), the age of an individual is the age

May 23, 2022 1120 Bulletin No. 2022–21
of that individual at the individual’s near-
est birthday. If the adjusted payout rate is
a percentage that is between the adjust-
ed payout rate for which factors are pro-
vided by Table U(1), an exact method of
obtaining the applicable factors (such as
through software using the actual rate of
return and the actuarial formula provided
in §1.664-4(e)(5)(i)) or a linear interpo-
lation must be used, provided whichever
method used is applied consistently. The
rules provided in §1.664-4(e)(5) apply
for determining the present value of the
remainder interest. See §1.664-4(e)(5)
for an example illustrating the applica-
tion of this paragraph (g)(5) (using cur-
rent actuarial tables).
(6) Actuarial Table U(1) for transfers
for which the valuation date is on or af-
ter May 1, 2009, and before [applicabili-
ty date of the Treasury decision adopting
these regulations as final regulations]. For
transfers for which the valuation date is on
or after May 1, 2009, and before [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations],
and without regard to the headings in the
tables in this paragraph (g)(6) that do not
contain this termination date for the ap-
plicability of the tables, the present value
of a charitable remainder unitrust interest
that is dependent on the termination of
a life interest is determined by using the
section 7520 rate, Table U(1) in this para-
graph (g)(6), and Tables F(4.2) through
F(14.0) in §1.664-4(e)(6)(iii). See, how-
ever, §1.7520-3(b) (relating to exceptions
to the use of prescribed tables under cer-
tain circumstances). Actuarial factors that
do not appear in the following tables may
be computed directly by using the formu-
la in §1.664-4(e)(5)(i) to derive factors
from the appropriate mortality table. For
the convenience of taxpayers, actuarial
factors have been computed by IRS and
appear in Table U(1) that is referenced
and explained by IRS Publication 1458,
“Actuarial Valuations Version 3B” (2009).
The table is available at no charge, elec-
tronically via the IRS website at https://
www.irs.gov/retirement-plans/actuari-
al-tables (or a corresponding URL as may
be updated from time to time).
* * * * *
(7) Applicability dates. Paragraphs
(g)(1) through (6) of this section apply
on and after May 1, 2009, and before
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations].
Par. 11. Section 1.7520-1 is amended
by revising paragraphs (a)(1) and (2), (b)
(2), (c), and (d) and adding paragraphs (e)
and (f) to read as follows:
§1.7520-1 Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests.
(a) * * * (1) Except as otherwise pro-
vided in this section and in §1.7520-3
(relating to exceptions to the use of pre-
scribed tables under certain circumstanc-
es), in the case of certain transactions after
April 30, 1989, subject to income tax, the
fair market value of annuities, interests for
life or a term of years (including unitrust
interests), and remainder or reversionary
interests is their present value determined
under this section. See §20.2031-7(d) of
this chapter (and, for periods prior to [ap-
plicability date of the Treasury decision
adopting these regulations as final regu-
lations], §20.2031-7A of this chapter) for
the computation of the value of annuities,
interests for life or a term of years, and
remainder or reversionary interests other
than interests described in paragraphs (a)
(2) and (3) of this section.
(2) For a transfer to a pooled income
fund, see §1.642(c)-6(e) (or, for periods
prior to [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], §1.642(c)-6A) with
respect to the valuation of the remainder
interest.
* * * * *
(b) * * *
(2) Mortality component. The mortal-
ity component reflects the mortality data
most recently available from the United
States census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described in
this section will be revised and the revised
mortality component tables will be pub-
lished in the IRS publications at that time.
For transactions with valuation dates on
or after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], the mortality component
table (Table 2010CM) is in §20.2031-7(d)
(7)(ii) of this chapter, is referenced by IRS
Publication 1457, “Actuarial Valuations
Version 4A,” and can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables (or a corre-
sponding URL as may be updated from
time to time). See §20.2031-7A of this
chapter for mortality component tables
applicable to transactions for which the
valuation date falls before [applicability
date of the Treasury decision adopting
these regulations as final regulations].
(c) Actuarial factors. The present
value on the valuation date of an annui-
ty, an interest for life or a term of years,
and a remainder or reversionary interest
is computed by using the section 7520
interest rate component that is described
in paragraph (b)(1) of this section and the
mortality component that is described in
paragraph (b)(2) of this section. Actuarial
factors for determining these present val-
ues may be calculated by taxpayers using
the actuarial formulas in §20.2031-7(d)(2)
of this chapter but, for the convenience of
taxpayers, are included in tables that are
referenced and explained by publications
of the Internal Revenue Service. If a spe-
cial factor is required in order to value an
interest, the special factor may be calcu-
lated by taxpayers using the actuarial for-
mulas in §20.2031-7(d)(2) of this chapter
or the taxpayer may request a ruling to ob-
tain the factor from the Internal Revenue
Service. The request for a ruling must be
accompanied by a recitation of the facts,
including the date of birth for each mea-
suring life and copies of relevant instru-
ments. A request for a ruling must comply
with the instructions for requesting a rul-
ing published periodically in the Internal
Revenue Bulletin (see Rev. Proc. 2021-1,
2021-1 I.R.B. 1, and subsequent updates,
and §§ 601.201 and 601.601(d)(2)(ii)(b)
of this chapter) and must include payment
of the required user fee.
(d) IRS publications referencing and
explaining actuarial tables with rates
from 0.2 to 20 percent, inclusive, at in-
tervals of two-tenths of one percent, for
valuation dates on or after [applicability
date of the Treasury decision adopting
these regulations as final regulations].
The publications listed in paragraphs (d)
(1) through (3) of this section will be
available after [date of publication of the
final rule in the Federal Register]. The
underlying actuarial tables referenced and
explained by these publications will be

Bulletin No. 2022–21 1121 May 23, 2022
available beginning May 5, 2022, at no
charge, electronically via the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables:
(1) IRS Publication 1457, “Actuari-
al Valuations Version 4A” (2022). This
publication references tables of valuation
factors and provides examples that show
how to compute other valuation factors,
for determining the present value of annu-
ities, interests for life or a term of years,
and remainder or reversionary interests,
measured by one or two lives. These fac-
tors may also be used in the valuation of
interests in a charitable remainder annuity
trust as defined in §1.664-2 and a pooled
income fund as defined in §1.642(c)-5.
This publication references and explains
Table S (single life remainder factors),
Table R(2) (two-life last-to-die remainder
factors), Table B (actuarial factors used
in determining the present value of an in-
terest for a term of years), Table H (com-
mutation factors), Table J (term certain
annuity beginning-of-interval adjustment
factors), and Table K (annuity end-of-in-
terval adjustment factors). See earlier ver-
sions of the publication, §1.642(c)-6A, or
§20.2031-7A of this chapter for Table S
applicable to valuation dates before [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions]. Earlier versions of the publication
also contain earlier versions of Table R(2).
Table B, Table J, and Table K also can be
found in §20.2031-7(d)(6) of this chapter,
but only for interest rates from 4.2 to 14
percent, inclusive.
(2) IRS Publication 1458, “Actuari-
al Valuations Version 4B” (2022). This
publication references and explains term
certain tables and tables of one and two
life valuation factors for determining the
present value of remainder interests in a
charitable remainder unitrust as defined
in §1.664-3. This publication references
Table U(1) (unitrust single life remainder
factors), Table U(2) (unitrust two-life last-
to-die remainder factors), Table D (actuar-
ial factors used in determining the present
value of a remainder interest postponed
for a term of years), Table F (adjustment
payout rate factors), and Table Z (unitrust
commutation factors). See earlier ver-
sions of the publication or §1.664-4A for
Table U(1) applicable to valuation dates
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations]. Earlier versions of the
publication also contain earlier versions of
Table U(2). Table D also can be found in
§1.664-4(e)(6)(iii), but only for adjusted
payout rates from 4.2 to 14 percent, inclu-
sive. Table F also can be found in §1.664-
4(e)(6)(iii), but only for interest rates from
4.2 to 14 percent, inclusive.
(3) IRS Publication 1459, “Actuarial
Valuations Version 4C” (2022). This pub-
lication references and explains Table C,
which provides factors for making adjust-
ments to the standard remainder factor for
valuing gifts of depreciable property. See
§1.170A-12.
(4) The publications identified in para-
graphs (d)(1) through (3) of this section
also reference Table 2010CM, the mortal-
ity component table.
(e) Use of approximation methods for
obtaining factors when the required val-
uation rate falls between two listed rates.
For certain cases, this part and IRS pub-
lications provide approximation methods
(for example, interpolation) for obtaining
factors when the required valuation rate
falls between two listed rates (such as in
the case of a pooled income fund’s rate of
return or a unitrust’s adjusted payout rate).
In general, exact methods of obtaining the
applicable factors are allowed, such as
through software using the applicable in-
terest rate and the proper actuarial formu-
la, provided such direct methods are ap-
plied consistently. The actuarial formula
in §20.2031-7(d)(2)(ii)(B) of this chapter
is used to determine the remainder factor
for pooled income funds and the actuarial
formula in §1.664-4(e)(5)(i) is used to de-
termine the remainder factor for unitrusts.
The approximation method provided in
this part must be used if more exact meth-
ods are not available.
(f) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
PART 20--ESTATE TAX; ESTATES
OF DECEDENTS DYING AFTER
AUGUST 16, 1954
Par. 12. The authority citation for part
20 continues to read in part as follows:
Authority:26 U.S.C. 7805.
* * * * *
Par. 13. Section 20.2031-0 is revised to
read as follows:
§20.2031-0 Table of contents.
This section lists the section headings
and undesignated center headings that ap-
pear in the regulations under section 2031.
§20.2031-1 Definition of gross estate; val-
uation of property.
§20.2031-2 Valuation of stocks and bonds.
§20.2031-3 Valuation of interests in
businesses.
§20.2031-4 Valuation of notes.
§20.2031-5 Valuation of cash on hand or
on deposit.
§20.2031-6 Valuation of household and
personal effects.
§20.2031-7 Valuation of annuities, inter-
ests for life or a term of years, and remain-
der or reversionary interests.
§20.2031-8 Valuation of certain life in-
surance and annuity contracts; valua-
tion of shares in an open-end investment
company.
§20.2031-9 Valuation of other property.
Actuarial Tables Applicable Before
[Applicability Date of the Treasury Deci-
sion Adopting These Regulations as Final
Regulations]
§20.2031-7A Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests for es-
tates of decedents for which the valuation
date of the gross estate is before [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations].
Par. 14. Section 20.2031-7 is amended
by:
1. Revising paragraph (c), the heading
of paragraph (d), and paragraphs (d)(1)
through (5).
2. Redesignating paragraph (d)(7) as
paragraph (g)(4) of §20.2031-7A.
3. Adding new paragraph (d)(7).
4. Revising paragraph (e).
The revisions and addition read as
follows:
§20.2031-7 Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests.
* * * * *

May 23, 2022 1122 Bulletin No. 2022–21
(c) Actuarial valuations. The present
value of annuities, interests for life or
a term of years, and remainder or rever-
sionary interests for estates of decedents
for which the valuation date of the gross
estate is on or after [applicability date of
the Treasury decision adopting these regu-
lations as final regulations], is determined
under paragraph (d) of this section. The
present value of annuities, interests for life
or a term of years, and remainder or rever-
sionary interests for estates of decedents
for which the valuation date of the gross
estate is before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations], is determined
under the following sections:
Table 1 to paragraph (c)
Valuation DatesApplicable Regulations
AfterBefore
-01-01-5220.2031-7A(a)
12-31-5101-01-7120.2031-7A(b)
12-31-7012-01-8320.2031-7A(c)
11-30-8305-01-8920.2031-7A(d)
04-30-8905-01-9920.2031-7A(e)
04-30-9905-01-0920.2031-7A(f)
04-30-09AD20.2031-7A(g)
AD = [applicability date of the Treasury decision adopting these regulations as final regulations].
(d) Actuarial valuations on or after
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations]--(1) In general. Except as
otherwise provided in paragraph (b) of
this section and §20.7520-3(b) (pertaining
to certain limitations on the use of pre-
scribed tables), if the valuation date for
the gross estate of the decedent is on or af-
ter [applicability date of the Treasury de-
cision adopting these regulations as final
regulations], the fair market value of an-
nuities, interests for life or a term of years,
and remainder or reversionary interests
is the present value determined by using
standard or special section 7520 actuarial
factors. These factors are derived by using
the actuarial formulas provided in para-
graph (d)(2) of this section, the appropri-
ate section 7520 interest rate, and, if ap-
plicable, the mortality component for the
valuation date of the interest that is being
valued. For purposes of the computations
described in this section, the age of an
individual is the age of that individual at
the individual’s nearest birthday. For the
convenience of taxpayers, paragraph (d)
(2) of this section provides for published
tables of factors for specific types of in-
terests. These published tables provide
factors for rates from 0.2 to 20 percent,
inclusive, at intervals of two-tenths of one
percent. In general, appropriate factors in-
stead may be computed directly from the
actuarial formulas provided in paragraph
(d)(2) of this section. In some cases, spe-
cific examples in this part and IRS pub-
lications illustrate approximation methods
(for example, interpolation) for obtaining
factors when the required valuation rate
falls between two listed rates (such as in
the case of a pooled income fund’s rate of
return or a unitrust’s adjusted payout rate).
Exact methods of obtaining the applica-
ble actuarial factors are allowed, such as
through software using the actual rate of
return and the actuarial formulas provided
in paragraph (d)(2) of this section; the ap-
proximation method provided in this part
must be used if more exact methods are
not available. See §§20.7520-1 through
20.7520-4.
(2) Specific interests--(i) Pooled in-
come funds and charitable remainder
trusts. The fair market value of a remain-
der interest in a pooled income fund, as
defined in §1.642(c)-5 of this chapter, is
its value determined under §1.642(c)-6(e).
The fair market value of a remainder inter-
est in a charitable remainder annuity trust,
as defined in §1.664-2(a), is the present
value determined under §1.664-2(c). The
fair market value of a remainder interest in
a charitable remainder unitrust, as defined
in §1.664-3, is its present value determined
under §1.664-4(e). The fair market value
of a life interest or an interest for a term of
years in a charitable remainder unitrust is
the fair market value of the property as of
the date of valuation less the fair market
value of the remainder interest on that date
determined under §1.664-4(e)(4) and (5).
(ii) Ordinary remainder and reversion-
ary interests--(A) Remainder and rever-
sionary interests for a term of years. If
the interest to be valued is a remainder or
reversionary interest to take effect after a
definite number of years, the present value
of the interest is computed by multiplying
the value of the property by the appropri-
ate remainder factor (that corresponds to
the applicable section 7520 interest rate
and the stated term). The factor for an or-
dinary remainder interest following a term
certain may be found using the formula in
Figure 1 to this paragraph (d)(2)(ii)(A).
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in Table B. Table B 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 B is referenced
and explained in IRS Publication 1457
“Actuarial Valuations Version 4A,” which
will be available after [date of publication

Bulletin No. 2022–21 1123 May 23, 2022
of the final rule in the Federal Register].
The remainder factors from Table B also
can be found in paragraph (d)(6) of this
section, but only for interest rates from
4.2 to 14 percent, inclusive. For informa-
tion about obtaining special factors for
other situations, see paragraph (d)(4) of
this section.
Figure 1 to paragraph (d)(2)(ii)(A) – Formula for determining term certain remainder factors
Figure 1 to paragraph (d)(2)(ii)(A) – Formula for determining term certain remainder factors

(B) Remainder and reversionary interests dependent on the life of one individual. If the
interest to be valued is a remainder or reversionary interest to take effect after the death of one
individual, the present value of the interest is computed by multiplying the value of the property
by the appropriate remainder factor (that corresponds to the applicable section 7520 interest rate
and the age of the measuring life of the life interest that precedes the remainder interest). The
factor for an ordinary remainder interest following the death of one individual may be found
using the formula in Figure 2 to this paragraph (d)(2)(ii)(B). The prescribed mortality table is
Table 2010CM as set forth in paragraph (d)(7)(ii) of this section, or for periods before
[applicability date of the Treasury decision adopting these regulations as final regulations], the
appropriate table found in §20.2031-7A. For the convenience of taxpayers, actuarial factors have
been computed by IRS and appear in Table S. Table S will be available beginning May 5, 2022,
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 S is referenced and
explained by IRS Publication 1457 "Actuarial Valuations Version 4A,” which will be available
after [date of publication of the final rule in the Federal Register]. For information about
obtaining special factors for other situations, see paragraph (d)(4) of this section.
Figure 2 to paragraph (d)(2)(ii)(B) – Formula for determining single life remainder factors
(B) Remainder and reversionary inter-
ests dependent on the life of one individual.
If the interest to be valued is a remainder or
reversionary interest to take effect after the
death of one individual, the present value
of the interest is computed by multiplying
the value of the property by the appropriate
remainder factor (that corresponds to the
applicable section 7520 interest rate and the
age of the measuring life of the life interest
that precedes the remainder interest). The
factor for an ordinary remainder interest
following the death of one individual may
be found using the formula in Figure 2 to
this paragraph (d)(2)(ii)(B). The prescribed
mortality table is Table 2010CM as set
forth in paragraph (d)(7)(ii) of this section,
or for periods before [applicability date of
the Treasury decision adopting these regu-
lations as final regulations], the appropriate
table found in §20.2031-7A. For the conve-
nience of taxpayers, actuarial factors have
been computed by IRS and appear in Ta-
ble S. Table S will be available beginning
May 5, 2022, at no charge, electronically
via the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables (or a cor-
responding URL as may be updated from
time to time). Table S is referenced and
explained by IRS Publication 1457 “Ac-
tuarial Valuations Version 4A,” which will
be available after [date of publication of
the final rule in the Federal Register]. For
information about obtaining special factors
for other situations, see paragraph (d)(4) of
this section.
Figure 2 to paragraph (d)(2)(ii)(B) – Formula for determining single life remainder factors

(iii) Ordinary interests for a term of years and life interests. If the interest to be valued is
the right of a person to receive the income of certain property, or to the use of certain property,
for a term of years or for the life of one individual, the present value of the interest is computed
by multiplying the value of the property by the appropriate actuarial factor for an interest for a
term of years or for a life interest (that corresponds to the applicable section 7520 interest rate
and the durational period). The actuarial factor for an ordinary income interest for a term certain
may be found by subtracting from 1.000000 the factor for an ordinary remainder interest
following the same term certain that is determined under the formula in paragraph (d)(2)(ii)(A)
of this section. For the convenience of taxpayers, actuarial factors have been computed by IRS
and appear in the “Income Interest” column of Table B which 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). The actuarial factor for an ordinary income interest for the life of
one individual may be found by subtracting from 1.00000 the factor for an ordinary remainder
interest following the life of the same individual that is determined in paragraph (d)(2)(ii)(B) of
this section. For the convenience of taxpayers, actuarial factors have been computed by IRS and
appear in the “Life Estate” column of Table S. Table S (applicable when the valuation date is on
or after [applicability date of the Treasury decision adopting these regulations as final
regulations]) can be found on the IRS website at https://www.irs.gov/retirement-plans/actuarial-
(iii) Ordinary interests for a term of
years and life interests. If the interest to be
valued is the right of a person to receive
the income of certain property, or to the
use of certain property, for a term of years
or for the life of one individual, the present
value of the interest is computed by mul-
tiplying the value of the property by the
appropriate actuarial factor for an interest

May 23, 2022 1124 Bulletin No. 2022–21
for a term of years or for a life interest
(that corresponds to the applicable section
7520 interest rate and the durational pe-
riod). The actuarial factor for an ordinary
income interest for a term certain may be
found by subtracting from 1.000000 the
factor for an ordinary remainder interest
following the same term certain that is de-
termined under the formula in paragraph
(d)(2)(ii)(A) of this section. For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear
in the “Income Interest” column of Table
B which 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). The
actuarial factor for an ordinary income
interest for the life of one individual may
be found by subtracting from 1.00000 the
factor for an ordinary remainder interest
following the life of the same individual
that is determined in paragraph (d)(2)(ii)
(B) of this section. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in the “Life
Estate” column of Table S. Table S (ap-
plicable when the valuation date is on or
after [applicability date of the Treasury
decision adopting these regulations as
final regulations]) can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables. Table B and
Table S are referenced and explained by
IRS Publication 1457 “Actuarial Valua-
tions Version 4A”. See §20.2031-7A or
earlier versions of Publication 1457 for
valuation of interests before [applicabili-
ty date of the Treasury decision adopting
these regulations as final regulations]. For
information about obtaining special fac-
tors for other situations, see paragraph (d)
(4) of this section.
(iv) Annuities. (A) If the interest to be
valued is the right of a person to receive an
annuity that is payable at the end of each
year for a term of years or for the life of
one individual, the present value of the
interest is computed by multiplying the
aggregate amount payable annually by
the appropriate annuity factor (that cor-
responds to the applicable section 7520
interest rate and annuity period). The
appropriate annuity factor for an annuity
payable for a term of years is computed by
subtracting from 1.000000 the factor for
an ordinary remainder interest following
the same term certain that is determined
under the formula in paragraph (d)(2)(ii)
(A) of this section and then dividing the
result by the applicable section 7520 in-
terest rate expressed as a number with at
least four decimal places. For the conve-
nience of taxpayers, actuarial factors have
been computed by IRS and appear in the
“Annuity” column of Table B which can
be found on the IRS website at https://
www.irs.gov/retirement-plans/actuar-
ial-tables (or a corresponding URL as
may be updated from time to time). The
appropriate annuity factor for an annuity
payable for the life of one individual is
computed by subtracting from 1.00000
the factor for an ordinary remainder inter-
est following the life of the same individ-
ual that is determined under the formula
in paragraph (d)(2)(ii)(B) of this section
and then dividing the result by the appli-
cable section 7520 interest rate expressed
as a number with four decimal places. For
the convenience of taxpayers, actuarial
factors have been computed by IRS and
appear in the “Annuity” column of Table
S. Table S (applicable when the valuation
date is on or after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations]) can be found
on the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. Table B
and Table S are referenced and explained
in IRS Publication 1457 “Actuarial Valu-
ations Version 4A”. See §20.2031-7A or
earlier versions of Publication 1457 for
valuation of interests before [applicabili-
ty date of the Treasury decision adopting
these regulations as final regulations]. For
information about obtaining special fac-
tors for other situations, see paragraph (d)
(4) of this section.
(B) If the annuity is payable at the
end of semiannual, quarterly, monthly, or
weekly periods, the product obtained by
multiplying the annuity factor by the ag-
gregate amount payable annually is then
multiplied by the applicable adjustment
factor at the appropriate interest rate com-
ponent for payments made at the end of
the specified periods. The applicable ad-
justment factor may be found using the
formula in Figure 3 to this paragraph (d)
(2)(iv)(B). For the convenience of taxpay-
ers, actuarial factors have been comput-
ed by IRS and appear in Table K. Table
K, which is referenced and explained by
Publication 1457, can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables. The provi-
sions of this paragraph (d)(2)(iv)(B) are
illustrated by the example in paragraph (d)
(2)(iv)(B)(2) of this section.
Figure 3 to paragraph (d)(2)(iv)(B) – Formula for determining annuity adjustment factor at the end of the specified period
Version 4A”. See §20.2031-7A or earlier versions of Publication 1457 for valuation of interests
before [applicability date of the Treasury decision adopting these regulations as final
regulations]. For information about obtaining special factors for other situations, see paragraph
(d)(4) of this section.
(B) If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly
periods, the product obtained by multiplying the annuity factor by the aggregate amount payable
annually is then multiplied by the applicable adjustment factor at the appropriate interest rate
component for payments made at the end of the specified periods. The applicable adjustment
factor may be found using the formula in Figure 3 to this paragraph (d)(2)(iv)(B). For the
convenience of taxpayers, actuarial factors have been computed by IRS and appear in Table K.
Table K, which is referenced and explained by Publication 1457, can be found on the IRS
website at https://www.irs.gov/retirement-plans/actuarial-tables. The provisions of this
paragraph (d)(2)(iv)(B) are illustrated by the example in paragraph (d)(2)(iv)(B)(2) of this
section.
Figure 3 to paragraph (d)(2)(iv)(B) – Formula for determining annuity adjustment factor at the
end of the specified period

(1) Sample factors from actuarial Table S and Table K. For purposes of the example in
paragraph (d)(2)(iv)(B)(2) of this section, the following factors from Table S and Table K will be
used:
Table 2 to paragraph (d)(2)(iv)(B)(1)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
(1) Sample factors from actuarial Ta-
ble S and Table K. For purposes of the
example in paragraph (d)(2)(iv)(B)(2) of
this section, the following factors from
Table S and Table K will be used:

Bulletin No. 2022–21 1125 May 23, 2022
Table 2 to paragraph (d)(2)(iv)(B)(1)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
AgeAnnuityLife EstateRemainder
759.40530.300970.69903
Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest RateSemi-AnnuallyQuarterlyMonthly
3.2%1.00791.01191.0146
(2) Example. At the time of the decedent’s death,
the survivor/annuitant, age 75, is entitled to receive
an annuity of $15,000 per year for life payable in
equal monthly installments at the end of each month.
The section 7520 rate for the month in which the
decedent died is 3.2 percent. Under Table S, the
annuity factor at 3.2 percent for an individual aged
75 is 9.4053. Under Table K, the adjustment factor
under the column for payments made at the end of
each monthly period at the rate of 3.2 percent is
1.0146. The aggregate annual amount, $15,000, is
multiplied by the factor 9.4053 and the product then
is multiplied by 1.0146. The present value of the an-
nuity at the date of the decedent’s death is, therefore,
$143,139.26 ($15,000 × 9.4053 × 1.0146).
(C) If an annuity is payable at the be-
ginning of annual, semiannual, quarterly,
monthly, or weekly periods for a term of
years, the value of the annuity is comput-
ed by multiplying the aggregate amount
payable annually by the annuity factor
described in paragraph (d)(2)(iv)(A) of
this section; and the product so obtained
then is multiplied by the applicable ad-
justment factor at the appropriate interest
rate component for payments made at the
beginning of specified periods. The ap-
plicable adjustment factor may be found
using the formula in Figure 4 to this para-
graph (d)(2)(iv)(C). For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table J.
Table J, which is referenced and explained
by Publication 1457, can be found on the
IRS website at https://www.irs.gov/retire-
ment-plans/actuarial-tables. If an annui-
ty is payable at the beginning of annual,
semiannual, quarterly, monthly, or weekly
periods for one or more lives, the value of
the annuity is the sum of the first payment
plus the present value of a similar annui-
ty, the first payment of which is not to be
made until the end of the payment period,
determined as provided in paragraph (d)
(2)(iv)(B) of this section.
Figure 4 to paragraph (d)(2)(iv)(C) – Formula for determining annuity adjustment factor at the beginning of the specified period
Figure 4 to paragraph (d)(2)(iv)(C) – Formula for determining annuity adjustment factor at the
beginning of the specified period

(v) Annuity and unitrust interests for a term of years or until the prior death of an
individual. See §25.2512-5(d)(2)(v) of this chapter for examples explaining how to compute the
present value of an annuity or unitrust interest that is payable until the earlier of the lapse of a
specific number of years or the death of an individual.
(3) Transitional rule. If a decedent dies on or after January 1, 2021, and before
[applicability date of the Treasury decision adopting these regulations as final regulations], the
fair market value of annuities, interests for life or a term of years, and remainder or reversionary
interests based on one or more measuring lives included in the gross estate of the decedent is
their present value determined under this section by using the section 7520 interest rate for the
month in which the valuation date occurs (see §§20.7520-1(b) and 20.7520-2(a)(2)) and factors
derived from the selected mortality table, either Table 2010CM in paragraph (d)(7)(ii) of this
section or Table 2000CM in §20.2031-7A(g)(4), at the option of the donor or the decedent's
executor, as the case may be. For the convenience of taxpayers, actuarial factors based on Table
2010CM appear in the proposed version of Table S, and actuarial factors based on Table
2000CM appear in the current version of Table S, which will be available as provided in
paragraph (d)(4) of this section. The 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 valuation date. For example, gift and
income tax charitable deductions with respect to the same transfer must be determined based on
(v) Annuity and unitrust interests for a
term of years or until the prior death of
an individual. See §25.2512-5(d)(2)(v) of
this chapter for examples explaining how
to compute the present value of an annuity
or unitrust interest that is payable until the
earlier of the lapse of a specific number of
years or the death of an individual.
(3) Transitional rule. If a decedent dies
on or after January 1, 2021, and before
[applicability date of the Treasury decision
adopting these regulations as final regula-
tions], the fair market value of annuities,
interests for life or a term of years, and
remainder or reversionary interests based
on one or more measuring lives includ-
ed in the gross estate of the decedent is
their present value determined under this
section by using the section 7520 interest
rate for the month in which the valua-
tion date occurs (see §§20.7520-1(b) and
20.7520-2(a)(2)) and factors derived from
the selected mortality table, either Table
2010CM in paragraph (d)(7)(ii) of this
section or Table 2000CM in §20.2031-
7A(g)(4), at the option of the donor or the
decedent’s executor, as the case may be.
For the convenience of taxpayers, actuari-
al factors based on Table 2010CM appear
in the proposed version of Table S, and
actuarial factors based on Table 2000CM
appear in the current version of Table S,
which will be available as provided in

May 23, 2022 1126 Bulletin No. 2022–21
paragraph (d)(4) of this section. The dece-
dent’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 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.
(4) Publications and actuarial compu-
tations by the Internal Revenue Service.
The factor for determining the present
value of a remainder interest that is depen-
dent on the termination of the life of one
individual may be computed by using the
formula in paragraph (d)(2)(ii)(B) of this
section to derive factors from the appro-
priate mortality table. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table S.
The factor for determining the present
value of a remainder interest following a
term certain may be computed by using
the formula in paragraph (d)(2)(ii)(A) of
this section. For the convenience of tax-
payers, actuarial factors have been com-
puted by IRS and appear in Table B. Ad-
justment factors for term certain annuities
payable at the beginning of each interval
may be computed by using the formula
in paragraph (d)(2)(iv)(C) of this section.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in Table J. Adjustment factors for
annuities payable at the end of each inter-
val may be computed by using the formula
in paragraph (d)(2)(iv)(B) of this section.
For the convenience of taxpayers, actu-
arial factors have been computed by IRS
and appear in Table K. These tables will
be available beginning May 5, 2022, 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).
IRS Publication 1457, “Actuarial Valua-
tions Version 4A” (2022), references and
explains the factors contained in the ac-
tuarial tables and also includes examples
that illustrate how to compute many spe-
cial factors for more unusual situations.
This publication will be available after
[date the Treasury decision adopting these
regulations as final regulations is pub-
lished in the Federal Register]. Table B,
Table J, and Table K also can be found in
paragraph (d)(6) of this section, but only
for interest rates from 4.2 to 14 percent,
inclusive. If a special factor is required in
the case of an actual decedent, the special
factor may be calculated by the executor
using the actuarial formulas in paragraph
(d)(2) of this section or the executor may
request a ruling to obtain the factor from
the Internal Revenue Service. The request
for a ruling must be accompanied by a rec-
itation of the facts including a statement of
the date of birth for each measuring life,
the date of the decedent’s death, any other
applicable dates, and a copy of the will,
trust, or other relevant documents. A re-
quest for a ruling must comply with the
instructions for requesting a ruling pub-
lished periodically in the Internal Revenue
Bulletin (see §§601.201 and 601.601(d)
(2)(ii)(b) of this chapter) and must include
payment of the required user fee.
(5) Examples. The provisions of this section are
illustrated by the examples in this paragraph (d)(5).
For purposes of these examples, the following fac-
tors from Table S, Table B, and Table K will be used:
Table 3 to paragraph (d)(5)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
AgeAnnuityLife EstateRemainder
3123.83340.762670.23733
4620.01460.640470.35953
Interest at 4.6 Percent
AgeAnnuityLife EstateRemainder
6511.76910.541380.45862
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 2.6 Percent
YearsAnnuityIncome InterestRemainder
54.63250.1204450.879555
Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest RateSemi-AnnuallyQuarterlyMonthly
2.6%1.00651.00971.0119
3.2%1.00791.01191.0146

Bulletin No. 2022–21 1127 May 23, 2022
(i) Example 1: Remainder payable at an indi-
vidual’s death. The decedent, or the decedent’s es-
tate, was entitled to receive certain property worth
$50,000 upon the death of A, to whom the income
was bequeathed for life. At the time of the decedent’s
death, A was 65 years and 5 months old. In the month
in which the decedent died, the section 7520 rate was
4.6 percent. Under Table S, the remainder factor at
4.6 percent for determining the present value of the
remainder interest due at the death of a person aged
65, A’s age at A’s nearest birthday to the date of the
decedent’s death, is 0.45862. The present value of
the remainder interest at the date of the decedent’s
death is, therefore, $22,931 ($50,000 times 0.45862).
(ii) Example 2: Income payable for an individ-
ual’s life. A’s parent bequeathed an income interest
in property to A for life, with the remainder interest
passing to B at A’s death. At the time of the parent’s
death, the value of the property was $50,000 and A
was 30 years and 10 months old. The section 7520
rate at the time of the parent’s death was 3.2 percent.
Under Table S, the factor at 3.2 percent for deter-
mining the present value of the life estate given to a
person aged 31, A’s age at A’s nearest birthday to the
date of the decedent’s death, is 0.76267. The present
value of A’s income interest at the time of the par-
ent’s death is, therefore, $38,133.50 ($50,000.00 ×
0.76267).
(iii) Example 3: Annuity payable for an individ-
ual’s life. A purchased an annuity for the benefit of
both A and B. Under the terms of the annuity con-
tract, at A’s death, a survivor annuity of $10,000 per
year, payable in equal semiannual installments made
at the end of each interval is payable to B for life. At
A’s death, B was 45 years and 7 months old. Also, at
A’s death, the section 7520 rate was 3.2 percent. Un-
der Table S, the factor at 3.2 percent for determining
the present value of an annuity interest payable until
the death of a person age 46 (B’s age at B’s nearest
birthday to the date of A’s death) is 20.0146. The ad-
justment factor from Table K at an interest rate of
3.2 percent for semiannual annuity payments made
at the end of the period is 1.0079. The present value
of the annuity at the date of A’s death is, therefore,
$201,727.15 ($10,000 × 20.0146 × 1.0079).
(iv) Example 4: Annuity payable for a term of
years. The decedent, or the decedent’s estate, was
entitled to receive an annuity of $10,000 per year
payable in equal quarterly installments at the end of
each quarter throughout a term certain. At the time of
the decedent’s death, the section 7520 rate was 2.6
percent. A quarterly payment had been made imme-
diately prior to the decedent’s death and payments
were to continue for 5 more years. Under Table B
for the interest rate of 2.6 percent, the factor for the
present value of an annuity with a term of 5 years
is 4.6325. The adjustment factor from Table K at an
interest rate of 2.6 percent for quarterly annuity pay-
ments made at the end of the quarter is 1.0097. The
present value of the annuity is, therefore, $46,774.35
($10,000 × 4.6325 × 1.0097).
* * * * *
(7) Actuarial Table S and Table 2010CM
where the valuation date is on or after [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions]--(i) Determination of required fac-
tors. Except as provided in §20.7520-3(b)
(pertaining to certain limitations on the use
of prescribed tables), for determination of
the present value of a remainder interest
that is dependent on the termination of a
life interest, where the valuation date is on
or after [applicability date of the Treasury
decision adopting these regulations as final
regulations], actuarial factors computed di-
rectly by using the formula in paragraph (d)
(2)(ii)(B) of this section, Table 2010CM,
and the section 7520 rate are used in the
application of the provisions of this section.
For the convenience of taxpayers, the actu-
arial factors, when the section 7520 interest
rate component is from 0.2 to 20 percent,
inclusive, have been computed by IRS and
can be found in Table S. Table S will be
available beginning May 5, 2022, at no
charge, electronically via the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables. Table S is also referenced
and explained by IRS Publication 1457
“Actuarial Valuations Version 4A,” which
will be available after [date the Treasury
decision adopting these regulations as fi-
nal regulations is published in the Federal
Register].
(ii) Table 2010CM.
Table 4 to paragraph (d)(7)(ii)
Age xl
x
Age xl
x
Age xl
x
0100,000.00 3797,193.66 7471,177.55
199,382.28 3897,058.84 7569,174.83
299,341.16 3996,915.25 7667,044.59
399,313.80 4096,761.20 7764,773.93
499,292.72 4196,595.51 7862,366.05

599,276.45 4296,416.30 7959,795.50
699,261.55 4396,220.61 8057,080.84
799,248.33 4496,005.41 8154,213.71
899,236.50 4595,768.60 8251,205.27
999,226.09 4695,509.98 8348,059.88

1099,217.03 4795,229.06 8444,808.51
1199,208.80 4894,923.45 8541,399.79
1299,199.98 4994,589.88 8637,895.25
1399,188.21 5094,225.50 8734,313.98
1499,170.64 5193,828.33 8830,700.82

May 23, 2022 1128 Bulletin No. 2022–21
Age xl
x
Age xl
x
Age xl
x
1599,145.34 5293,398.01 8927,106.68
1699,111.91 5392,934.52 9023,586.75
1799,070.69 5492,438.08 9120,198.02
1899,021.50 5591,907.95 9216,996.17
1998,964.16 5691,342.02 9314,032.08

2098,898.61 5790,737.24 9411,348.23
2198,824.20 5890,090.97 958,975.661
2298,741.32 5989,401.06 966,931.559
2398,652.16 6088,665.95 975,218.261
2498,559.87 6187,883.66 983,823.642

2598,466.80 6287,051.88 992,722.994
2698,373.71 6386,167.86 1001,882.108
2798,280.09 6485,226.77 1011,261.083
2898,185.51 6584,221.59 102818.2641
2998,089.05 6683,142.34 103513.7236

3097,989.90 6781,978.28 104311.8784
3197,887.47 6880,728.83 105183.0200
3297,781.58 6979,387.95 106103.8046
3397,672.13 7077,957.53 10756.91106
3497,559.20 7176,429.84 10830.17214

3597,442.53 7274,797.63 10915.47804
3697,321.14 7373,049.33 1100.000000
(e) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 15. The undesignated center head-
ing immediately preceding §20.2031-7A
is revised to read as follows:
Actuarial Tables Applicable Before
[Applicability Date of the Treasury Deci-
sion Adopting These Regulations as Final
Regulations]
Par. 16. Section 20.2031-7A is amend-
ed by:
1. Revising the section heading.
2. Adding paragraphs (g) heading and
(g)(1) through (3).
3. In newly redesignated paragraph (g)
(4), the heading and introductory text are
revised.
4. Adding paragraph (g)(5).
The revisions and additions read as
follows:
§20.2031-7A Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests
for estates of decedents for which the
valuation date of the gross estate is
before [applicability date of the Treasury
decision adopting these regulations as
final regulations].
* * * * *
(g) Valuation of annuities, interests for
life or a term of years, and remainder or
reversionary interests for estates of dece-
dents for which the valuation date of the
gross estate is on or after May 1, 2009,
and before [applicability date of the Trea-
sury decision adopting these regulations
as final regulations]--(1) In general. Ex-
cept as otherwise provided in §§20.2031-
7(b) and 20.7520-3(b) (pertaining to cer-
tain limitations on the use of prescribed
tables), if the valuation date for the gross
estate of the decedent is on or after May
1, 2009, and before [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations], the fair mar-
ket value of annuities, interests for life or
a term of years, and remainder or rever-
sionary interests is the present value of the
interests determined by using standard or
special section 7520 actuarial factors and
the valuation methodology described in
§20.2031-7(d). These factors are derived
by using the appropriate section 7520 in-
terest rate and, if applicable, the mortality
component for the valuation date of the in-
terest that is being valued. See §§20.7520-
1 through 20.7520-4. See paragraph (g)
(4) of this section for determination of the
appropriate table for use in valuing these
interests.
(2) Transitional rules. (i) If a decedent
dies on or after May 1, 2009, and if, on
May 1, 2009, the decedent was under a

Bulletin No. 2022–21 1129 May 23, 2022
mental disability so that the disposition
of the decedent’s property could not be
changed, and the decedent dies before [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions] either without having regained the
ability to dispose of the decedent’s proper-
ty or within 90 days of the date on which
the decedent first regains that ability, the
fair market value of annuities, interests
for life or a term of years, and remainder
or reversionary interests included in the
gross estate of the decedent is their present
value determined either under this section
or under the corresponding section appli-
cable at the time the decedent first became
subject to the mental disability, at the op-
tion of the decedent’s executor. For exam-
ple, see paragraph (d) of this section.
(ii) If a decedent dies on or after May
1, 2009, and before July 1, 2009, the fair
market value of annuities, interests for life
or a term of years, and remainder or re-
versionary interests based on one or more
measuring lives included in the gross es-
tate of the decedent is their present val-
ue determined under this section by us-
ing the section 7520 interest rate for the
month in which the valuation date occurs
(see §§20.7520-1(b) and 20.7520-2(a)
(2)) and the appropriate actuarial tables
under either paragraph (f)(4) or (g)(4) of
this section, at the option of the decedent’s
executor.
(iii) For purposes of paragraphs (g)
(2)(i) and (ii) of this section, where the
decedent’s executor is given the option to
use the appropriate actuarial tables under
either paragraph (f)(4) or (g)(4) of this
section, the decedent’s executor must con-
sistently use the same mortality basis with
respect to each interest (income, remain-
der, partial, etc.) in the same property, and
with respect to all transfers occurring on
the valuation date. For example, gift and
income tax charitable deductions with
respect to the same transfer must be de-
termined based on factors with the same
mortality basis, and all assets includible
in the gross estate and/or estate tax de-
ductions claimed must be valued based on
factors with the same mortality basis.
(3) Publications and actuarial compu-
tations by the Internal Revenue Service.
The factor for determining the present
value of a remainder interest that is depen-
dent on the termination of the life of one
individual may be computed by using the
formula in §20.2031-7(d)(2)(ii)(B) to de-
rive factors from the appropriate mortality
table. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table S. The factor
for determining the present value of a re-
mainder interest following a term certain
may be computed by using the formula in
§20.2031-7(d)(2)(ii)(A). For the conve-
nience of taxpayers, actuarial factors have
been computed by IRS and appear in Ta-
ble B. Adjustment factors for term certain
annuities payable at the beginning of each
interval may be computed by using the
formula in §20.2031-7(d)(2)(iv)(C). For
the convenience of taxpayers, actuarial
factors have been computed by IRS and
appear in Table J. Adjustment factors for
annuities payable at the end of each inter-
val may be computed by using the formula
in §20.2031-7(d)(2)(iv)(B). For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear
in Table K. These tables are referenced
and explained by IRS Publication 1457,
“Actuarial Values Version 3A,” (2009).
Publication 1457 includes examples that
illustrate how to compute many special
factors for more unusual situations. The
actuarial tables are available, at no charge,
electronically via the IRS website at
https://www.irs.gov/retirement-plans/ac-
tuarial-tables (or a corresponding URL as
may be updated from time to time). Table
S also can be found in paragraph (g)(4)
of this section, but only for interest rates
from 0.2 to 14 percent, inclusive. Table
B, Table J, and Table K also can be found
in §20.2031-7(d)(6), but only for interest
rates from 4.2 to 14 percent, inclusive. If a
special factor is required in the case of an
actual decedent, the special factor may be
calculated by the executor using the actu-
arial formulas in §20.2031-7(d)(2) or the
executor may request a ruling to obtain the
factor from the Internal Revenue Service.
The request for a ruling must be accompa-
nied by a recitation of the facts including
a statement of the date of birth for each
measuring life, the date of the decedent’s
death, any other applicable dates, and a
copy of the will, trust, or other relevant
documents. A request for a ruling must
comply with the instructions for request-
ing a ruling published periodically in the
Internal Revenue Bulletin (see §§601.201
and 601.601(d)(2)(ii)(b) of this chapter)
and must include payment of the required
user fee.
(4) Actuarial tables. Except as
provided in §20.7520-3(b) (pertaining
to certain limitations on the use of pre-
scribed tables), actuarial factors based on
Table 2000CM must be used in the appli-
cation of the provisions of this section.
The factor for determining the present
value of a remainder interest that is de-
pendent on the termination of the life of
one individual may be computed by us-
ing the formula in §20.2031-7(d)(2)(ii)
(B) to derive factors from the appropri-
ate mortality table. For the convenience
of taxpayers, actuarial factors, when the
section 7520 interest rate component is
from 0.2 to 20 percent, inclusive, have
been computed by IRS and appear in
Table S (applicable on and after May 1,
2009, and before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations]). These actu-
arial tables, as referenced and explained
by IRS Publication 1457 “Actuarial Val-
uations Version 3A,” are available, at no
charge, electronically via the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables. Table S (notwithstand-
ing the lack of the applicable termination
date in its heading), where the section
7520 interest rate component is from
0.2 to 14 percent, inclusive, and Table
2000CM are as follows:
* * * * *
(5) Applicability dates. Paragraphs (g)
(1) through (4) of this section apply on and
after May 1, 2009, and before [applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations].
Par. 17. Section 20.2032-1 is amended
by revising paragraphs (f)(1) and (h) to
read as follows:
§20.2032-1 Alternate valuation.
* * * * *
(f) * * *
(1) Life estates, remainders, and sim-
ilar interests--(i) In general. The values
of life estates, remainders, and similar
interests are to be obtained by applying
the methods prescribed in §20.2031-7, us-
ing the age of each person, the duration
of whose life may affect the value of the
interest, as of the date of the decedent’s

May 23, 2022 1130 Bulletin No. 2022–21
death, and the value of the property as of
the alternate valuation date.
(ii) Sample factors from actuarial Ta-
ble S. The present value of a remainder in-
terest dependent on the termination of one
life is determined by using the formula in
§20.2031-7(d)(2)(ii)(B) to derive factors
from the appropriate mortality table. For
the convenience of taxpayers, actuarial
factors have been computed by IRS and
appear in Table S. Table S 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). For purposes of the ex-
ample in paragraph (e)(5)(iii) of this sec-
tion, the following relevant factors from
Table S is used:
Table 2 to paragraph (f)(1)(ii)
Table S - Based on Table 2010CM
Interest at 4.2 Percent
AgeAnnuityLife EstateRemainder
6512.21280.512940.48706
Interest at 4.6 Percent
AgeAnnuityLife EstateRemainder
6511.76910.541380.45862
(iii) Example. Assume that the decedent, or the
decedent’s estate, was entitled to receive certain
property worth $50,000 upon the death of A, who
was entitled to the income for life. At the time of the
decedent’s death, A was 65 years and 5 months old,
and the section 7520 rate was 4.6 percent. The value
of the decedent’s remainder interest at the date of
the decedent’s death would, as illustrated in Example
1 of §20.2031-7(d)(5)(i), be $22,931.00 ($50,000 x
0.45862). On the date that is 6 months after the dece-
dent’s death, A was 65 years and 11 months old, and
the section 7520 rate was 4.2 percent. If, because of
economic conditions, the property declined in value
and was worth only $40,000 on the date that was 6
months after the date of the decedent’s death, and
the decedent’s executor elected to use the alternate
valuation date, the value of the remainder interest
would be $19,482.40 ($40,000 X 0.48706). When
the alternate valuation date is elected, the age of
A, and other aspects of valuation which change by
reason of the mere passage of time, is determined as
of the date of the decedent’s death, while the value
of the property and the relevant section 7520 inter-
est rate is determined as of the alternate valuation
date. Thus, the computation uses A’s age of 65 years
old at the date of the decedent’s death, even though
A would be closest to 66 years old on the alternate
valuation date.
* * * * *
(h) Applicability date. Paragraph (b)
of this section is applicable to decedents
dying on or after January 4, 2005. How-
ever, pursuant to section 7805(b)(7),
taxpayers may elect to apply paragraph
(b) of this section retroactively if the pe-
riod of limitations for filing a claim for
a credit or refund of Federal estate or
generation-skipping transfer tax under
section 6511 has not expired. Paragraph
(f)(1) of this section applies on and after
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations].
Section 20.2032-1T [Removed]
Par. 18. Section 20.2032-1T is
removed.
Par. 19. Section 20.2036-1 is amended:
1. In paragraph (c)(2)(iv) by designat-
ing Examples 1 through 8 as paragraphs
(c)(2)(iv)(A) through (H), respectively.
2. In newly designated paragraphs (c)
(2)(iv)(A), (B), (C), (G), and (H) by fur-
ther redesignating the paragraphs in the
first column as paragraphs in the second
column:
Old paragraphsNew paragraphs
(c)(2)(iv)(A)(i) and (ii)
(c)(2)(iv)(A)(1) and (2)
(c)(2)(iv)(B)(i) and (ii)
(c)(2)(iv)(B)(1) and (2)
(c)(2)(iv)(C)(i), (ii), and (iii)
(c)(2)(iv)(C)(1), (2), and (3)
(c)(2)(iv)(G)(i), (ii), and (iii)
(c)(2)(iv)(G)(1), (2), and (3)
(c)(2)(iv)(G)(3)(A), (B), (C), (D), (E), and (F)(c)(2)(iv)(G)(3)(i), (ii), (iii), (iv), (v), and (vi)
(c)(2)(iv)(G)(iv), (v), and (vi)
(c)(2)(iv)(G)(4), (5), and (6)
(c)(2)(iv)(H)(i), (ii), (iii), (iv), (v), (vi), and (vii)
(c)(2)(iv)(H)(1), (2), (3), (4), (5), (6), and (7)
3. By revising newly designated para-
graph (c)(2)(iv)(C).
The revision reads as follows:
§20.2036-1 Transfers with retained life
estate.
* * * * *
(c) * * *
(2) * * *
(iv) * * *
(C) Example 3. (1) D created a CRUT within the
meaning of section 664(d)(2). The trust instrument
directs the trustee to hold, invest, and reinvest the
corpus of the trust and to pay to D for D’s life, and
then to D’s child (C) for C’s life, in equal quarter-
ly installments payable at the end of each calendar
quarter, an amount equal to 6 percent of the fair mar-
ket value of the trust as valued on December 15 of
the prior taxable year of the trust. At the termination
of the trust, the then-remaining corpus, together with
any and all accrued income, is to be distributed to
N, a charitable organization described in sections
170(c), 2055(a), and 2522(a). D dies six years later,
survived by C, who was then age 55. The value of the
trust assets on D’s death was $300,000. D’s executor

Bulletin No. 2022–21 1131 May 23, 2022
does not elect to use the alternate valuation date and
D’s executor does not choose to use the section 7520
interest rate for either of the two months prior to D’s
death.
(2) The amount of the corpus with re-
spect to which D retained the right to the
income, and thus the amount includible in
D’s gross estate under section 2036(a)(1),
is that amount of corpus necessary to yield
the unitrust payments as interest on the
corpus. In this case, such amount of corpus
is determined by dividing the trust’s equiv-
alent income interest rate by the section
7520 rate (which was 5.4 percent at the
time of D’s death). The equivalent income
interest rate is determined by dividing the
trust’s adjusted payout rate by the excess
of 1 over the adjusted payout rate. Based
on Table F(5.4) in §1.664-4(e)(6)(iii) of
this chapter, the appropriate adjusted pay-
out rate for the trust at D’s death is 5.807
percent (6 percent × 0.967769). Thus, the
equivalent income interest rate is 6.165
percent (5.807 percent / (1 – 5.807 per-
cent)). The ratio of the equivalent interest
rate to the assumed interest rate under sec-
tion 7520 is 114.17 percent (6.165 percent
/ 5.4 percent). Because this exceeds 100
percent, D’s retained payout interest ex-
ceeds a full income interest in the trust, and
D effectively retained the income from all
the assets transferred to the trust. Accord-
ingly, because D retained for life an inter-
est at least equal to the right to all income
from all the property transferred by D to
the CRUT, the entire value of the corpus
of the CRUT is includible in D’s gross es-
tate under section 2036(a)(1). (The result
would be the same if D had retained, in-
stead, an interest in the CRUT for a term of
years and had died during the term.) Under
the facts presented, section 2039 does not
apply to include any amount in D’s gross
estate by reason of D’s retained unitrust in-
terest. See §20.2039-1(e).
(3) If, instead, D had retained the right
to a unitrust amount having an adjust-
ed payout for which the corresponding
equivalent interest rate would have been
less than the 5.4 percent assumed interest
rate of section 7520, then a correspond-
ingly reduced proportion of the trust cor-
pus would be includible in D’s gross estate
under section 2036(a)(1). Alternatively, if
the interest retained by D was instead only
one-half of the 6 percent unitrust interest,
then the amount included in D’s estate
would be the amount needed to produce
a 3 percent unitrust interest. All of the
results in this paragraph (c)(2)(iv)(C)(3)
(Example 3) would be the same if the trust
had been a grantor retained unitrust in-
stead of a CRUT.
* * * * *
Par. 20. Section 20.2055-2 is amended
by revising paragraphs (e)(3)(iii) and (f)
(4) and (6) to read as follows:
§20.2055-2 Transfers not exclusively for
charitable purposes.
* * * * *
(e) * * *
(3) * * *
(iii)(A) The rule in paragraphs (e)(2)
(vi)(a) and (e)(2)(vii)(a) of this section
that guaranteed annuity interests or uni-
trust interests, respectively, may be pay-
able for a specified term of years or for
the life or lives of only certain individ-
uals generally is effective in the case of
transfers pursuant to wills and revocable
trusts when the decedent dies on or after
April 4, 2000. Two exceptions from the
application of the rule in paragraphs (e)
(2)(vi)(a) and (e)(2)(vii)(a) of this section
are provided for transfers pursuant to a
will or revocable trust executed on or be-
fore April 4, 2000. One exception is for
a decedent who dies on or before July 5,
2001, without having republished the will
(or amended the trust) by codicil or other-
wise. The other exception is for a decedent
who was, on April 4, 2000, under a mental
disability that prevented a change in the
disposition of the decedent’s property, and
who either does not regain competence to
dispose of such property before the date
of death, or dies prior to the later of 90
days after the date on which the decedent
first regains competence, or July 5, 2001,
without having republished the will (or
amended the trust) by codicil or other-
wise. If a guaranteed annuity interest or
unitrust interest created pursuant to a will
or revocable trust when the decedent dies
on or after April 4, 2000, uses an individ-
ual other than one permitted in paragraphs
(e)(2)(vi)(a) and (e)(2)(vii)(a) of this sec-
tion, and the interest does not qualify for
this transitional relief, the interest may be
reformed into a lead interest payable for a
specified term of years. The term of years
is determined by taking the factor for
valuing the annuity or unitrust interest for
the named individual measuring life and
identifying the term of years (rounded up
to the next whole year) that corresponds to
the equivalent term of years factor for an
annuity or unitrust interest. A judicial ref-
ormation must be commenced prior to the
later of July 5, 2001, or the date prescribed
by section 2055(e)(3)(C)(iii). Any judicial
reformation must be completed within a
reasonable time after it is commenced. A
non-judicial reformation is permitted if
effective under state law, provided it is
completed by the date on which a judicial
reformation must be commenced. In the
alternative, if a court, in a proceeding that
is commenced on or before July 5, 2001,
declares any transfer made pursuant to a
will or revocable trust where the decedent
dies on or after April 4, 2000, and on or
before March 6, 2001, null and void ab
initio, the Internal Revenue Service will
treat such transfers in a manner similar to
that described in section 2055(e)(3)(J).
(B) The appropriate annuity factor for
an annuity payable for a term of years is
computed by subtracting from 1.000000
the factor for an ordinary remainder in-
terest following the same term certain
that is determined under the formula in
§20.2031-7(d)(2)(ii)(A) and then dividing
the result by the applicable section 7520
interest rate expressed as a number with
at least four decimal places. For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear
in the “Annuity” column of Table B. The
appropriate annuity factor for an annuity
payable for the life of one individual is
computed by subtracting from 1.00000
the factor for an ordinary remainder inter-
est following the life of the same individ-
ual that is determined under the formula in
§20.2031-7(d)(2)(ii)(B) and then dividing
the result by the applicable section 7520
interest rate expressed as a number with
four decimal places. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in the “An-
nuity” column of Table S. Table B and
Table S 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). For
purposes of the example in paragraph (e)
(3)(iii)(C) of this section, the following
relevant factors from Table B and Table S
are used:

May 23, 2022 1132 Bulletin No. 2022–21
Table 1 to paragraph (e)(3)(iii)(B)
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 3.2 Percent
YearsAnnuityIncome InterestRemainder
3721.50680.6882180.311782
3821.80890.6978860.302114
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
AgeAnnuityLife EstateRemainder
4021.70450.694540.30546
(C) The following example illustrates
how to determine the term of years for
a reformed interest as discussed in para-
graph (e)(3)(iii)(A) of this section. As-
sume an annuity interest payable for the
life of an individual age 40 at the time of
the transfer on or after [applicability date
of the Treasury decision adopting these
regulations as final regulations], with an
interest rate of 3.2 percent under section
7520. Under Table S, the annuity factor
at 3.2 percent for the life of an individual
age 40 is 21.7045. Based on Table B at 3.2
percent, the factor 21.7045 corresponds to
a term of years between 37 and 38 years.
Accordingly, the annuity interest must be
reformed into an interest payable for a
term of 38 years.
* * * * *
(f) * * *
(4) Other decedents. The present value
of an interest not described in paragraph
(f)(2) of this section is to be determined
under §20.2031-7(d) in the case of dece-
dents where the valuation date of the gross
estate is on or after [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations], or under
§20.2031-7A in the case of decedents
where the valuation date of the gross es-
tate is before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
* * * * *
(6) Applicability date. Paragraphs (e)
(3)(iii) and (f)(4) of this section apply on
and after [applicability date of the Trea-
sury decision adopting these regulations
as final regulations].
Par. 21. Section 20.2056A-4 is amend-
ed by:
1. Revising paragraph (c)(4)(ii)(B).
2. In paragraph (d), designating Ex-
amples 1 through 5 as paragraphs (d)(1)
through (5), respectively.
3. Revising the headings in newly des-
ignated paragraphs (d)(1) through (3).
4. Revising newly designated para-
graph (d)(4), newly designated paragraph
(d)(5) heading, and paragraph (e).
The revisions read as follows:
§20.2056A-4 Procedures for conforming
marital trusts and nontrust marital
transfers to the requirements of a
qualified domestic trust.
* * * * *
(c) * * *
(4) * * *
(ii) * * *
(B) The total present value of the non-
assignable annuity or other payment is
the present value of the annuity or other
payment as of the date of the decedent’s
death, determined in accordance with
the interest rates and mortality table pre-
scribed by section 7520. The expected
annuity term is the number of years that
would be required for the scheduled pay-
ments to exhaust a hypothetical fund equal
to the present value of the scheduled pay-
ments. This is determined by first dividing
the total present value of the payments by
the annual payment. From the quotient so
obtained, the expected annuity term is de-
rived by identifying the term of years that
corresponds to the lowest annuity factor
that is equal to or greater than the quotient.
The annuity factor is computed by sub-
tracting from 1.000000 the factor for an
ordinary remainder interest following the
same term certain that is determined un-
der the formula in §20.2031-7(d)(2)(ii)(A)
and then dividing the result by the applica-
ble section 7520 interest rate expressed as
a number with at least four decimal places.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in the “Annuity” column of Table
B which 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). If
the quotient obtained falls between two
terms, the longer term is used.
* * * * *
(d) * * *
(1) Example 1. Transfer and assignment of pro-
bate and nonprobate property to QDOT. * * *
(2) Example 2. Formula assignment. * * *
(3) Example 3. Jointly owned property. * * *
(4) Example 4. Computation of corpus portion of
annuity payment. (i) The appropriate annuity factor
for an annuity payable for the life of one individual
is computed by subtracting from 1.00000 the factor
for an ordinary remainder interest following the life
of the same individual that is determined under the
formula in §20.2031-7(d)(2)(ii)(B) and then dividing
the result by the applicable section 7520 interest rate
expressed as a number with four decimal places. For
the convenience of taxpayers, actuarial factors have
been computed by IRS and appear in the “Annuity”
column of Table S. The appropriate annuity factor
for an annuity payable for a term of years is com-
puted by subtracting from 1.000000 the factor for
an ordinary remainder interest following the same
term certain that is determined under the formula in
§20.2031-7(d)(2)(ii)(A) and then dividing the result
by the applicable section 7520 interest rate expressed
as a number with at least four decimal places. For

Bulletin No. 2022–21 1133 May 23, 2022
the convenience of taxpayers, actuarial factors have
been computed by IRS and appear in the “Annui-
ty” column of Table B. The applicable adjustment
factor for annuities that are payable at the end of
semiannual, quarterly, monthly, or weekly periods is
computed by use of the formula in §20.2031-7(d)(2)
(iv)(B). For the convenience of taxpayers, actuarial
factors have been computed by IRS and appear in
Table K. These actuarial tables can be found on the
IRS website at https://www.irs.gov/retirement-plans/
actuarial-tables. For purposes of the example in this
paragraph (d)(4), the relevant factors from Table S,
Table B, and Table K are:
Table 2 to paragraph (d)(4)
Factors from Table S - Based on Table 2010CM
Interest at 3.6 Percent
AgeAnnuityLife EstateRemainder
6014.69080.528870.47113
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 3.6 Percent
YearsAnnuityIncome InterestRemainder
2114.56050.5241770.475823
2215.01980.5407120.459288
Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest RateSemi-AnnuallyQuarterlyMonthly
3.6%1.00891.01341.0164
(ii) At the time of D’s death, on or after
[applicability date of the Treasury decision
adopting these regulations as final regula-
tions], D is a participant in an employees’
pension plan described in section 401(a).
On D’s death, D’s spouse S, a resident of
the United States, becomes entitled to re-
ceive a survivor’s annuity of $72,000 per
year, payable monthly, for life. At the time
of D’s death, S is age 60. Assume that un-
der section 7520, the appropriate discount
rate to be used for valuing annuities in the
case of this decedent is 3.6 percent. Under
Table S, the annuity factor at 3.6 percent
for a person age 60 is 14.6908. The ad-
justment factor at 3.6 percent in Table K
for monthly payments is 1.0164. Accord-
ingly, the right to receive $72,000 per year
on a monthly basis is equal to the right to
receive $73,180.80 ($72,000 x 1.0164) on
an annual basis.
(iii) The corpus portion of each annu-
ity payment received by S is determined
as follows:
(A) The first step is to determine the
present value of S’s annuity payments
under the plan ($73,180.80 × 14.6908 =
$1,075,084.50).
(B) The second step is to determine the
number of years that would be required
for S’s annuity to exhaust a hypothetical
fund of $1,075,084.50. The annuity fac-
tor of 14.6908 falls between the Table B
term certain annuity factors for 21 and 22
years at an interest rate of 3.6 percent. Ac-
cordingly, the expected annuity term is 22
years.
(C) The third step is to determine the
corpus amount of the annual payment by
dividing the expected term of 22 years
into the present value of the hypothetical
fund ($1,075,084.50 / 22 = $48,867.48).
(D) In the fourth step, the corpus por-
tion of each annuity payment is deter-
mined by dividing the corpus amount of
each annual payment by the annual annu-
ity payment (adjusted for payments more
frequently than annually as in paragraph
(d)(4)(i) of this section) ($48,867.48 /
73,180.80 = 0.67).
(iv) Accordingly, 67 percent of each
payment to S is deemed to be a distribution
of corpus. A marital deduction is allowed
for $1,075,084.50, the present value of the
annuity as of D’s date of death, if either:
S agrees to roll over the corpus portion of
each payment to a QDOT and the executor
files the Information Statement described
in paragraph (c)(5) of this section and the
Roll Over Agreement described in para-
graph (c)(7) of this section; or S agrees to
pay the tax due on the corpus portion of
each payment and the executor files the
Information Statement described in para-
graph (c)(5) of this section and the Pay-
ment Agreement described in paragraph
(c)(6) of this section.
(5) Example 5. Transfer to QDOT subject to gift
tax. * * *
* * * * *
(e) Applicability date. Paragraphs (c)
(4)(ii)(B) and (d)(4) of this section are ap-
plicable with respect to decedents dying
on or after [applicability date of the Trea-
sury decision adopting these regulations
as final regulations].
Par. 22. Section 20.7520-1 is amended
by revising paragraphs (a)(1) and (2), (b)
(2), (c), and (d) and adding paragraphs (e)
and (f) to read as follows:

May 23, 2022 1134 Bulletin No. 2022–21
§20.7520-1 Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests.
(a) * * *(1) Except as otherwise provid-
ed in this section and in §20.7520-3 (relat-
ing to exceptions to the use of prescribed
tables under certain circumstances), in the
case of estates of decedents with valuation
dates after April 30, 1989, the fair market
value of annuities, interests for life or a
term of years (including unitrust interests),
and remainder or reversionary interests is
their present value determined under this
section. See §20.2031-7(d) (and, for peri-
ods prior to [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], §20.2031-7A) for
the computation of the value of annuities,
interests for life or a term of years, and
remainder or reversionary interests, other
than interests described in paragraphs (a)
(2) and (3) of this section.
(2) For a transfer to a pooled income
fund, see §1.642(c)-6(e) of this chap-
ter (or, for periods prior to [applicability
date of the Treasury decision adopting
these regulations as final regulations],
§1.642(c)-6A) with respect to the valua-
tion of the remainder interest.
* * * * *
(b) * * *
(2) Mortality component. The mortal-
ity component reflects the mortality data
most recently available from the United
States census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described in
this section will be revised and the revised
mortality component tables will be pub-
lished in IRS publications at that time. For
decedents’ estates with valuation dates on
or after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], the mortality component
table (Table 2010CM) is in §20.2031-7(d)
(7)(ii) and is referenced by IRS Publica-
tion 1457, “Actuarial Valuations Version
4A,” and 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). See
§20.2031-7A for mortality component ta-
bles applicable to decedents’ estates with
valuation dates before [applicability date
of the Treasury decision adopting these
regulations as final regulations].
(c) Actuarial factors. The present
value on the valuation date of an annui-
ty, an interest for life or a term of years,
and a remainder or reversionary interest
is computed by using the section 7520
interest rate component that is described
in paragraph (b)(1) of this section and the
mortality component that is described in
paragraph (b)(2) of this section. Actuari-
al factors for determining these present
values may be calculated by using the for-
mulas in §20.2031-7(d)(2). For the conve-
nience of taxpayers, the IRS has computed
actuarial factors and displayed them on ta-
bles that are referenced and explained by
publications of the Internal Revenue Ser-
vice. If a special factor is required in order
to value an interest, the special factor may
be calculated by the taxpayer using the
actuarial formulas in §20.2031-7(d)(2) or
the taxpayer may request a ruling to ob-
tain the factor from the Internal Revenue
Service. The request for a ruling must be
accompanied by a recitation of the facts,
including the date of birth for each mea-
suring life and copies of relevant instru-
ments. A request for a ruling must comply
with the instructions for requesting a rul-
ing published periodically in the Internal
Revenue Bulletin (see Rev. Proc. 2021-1,
2021-1 I.R.B. 1, and subsequent updates,
and §§ 601.201 and 601.601(d)(2)(ii)(b)
of this chapter) and must include payment
of the required user fee.
(d) IRS publications referencing and
explaining actuarial tables with rates from
0.2 to 20 percent, inclusive, at intervals of
two-tenths of one percent, for valuation
dates on and after [applicability date of
the Treasury decision adopting these reg-
ulations as final regulations]. The publi-
cations listed in paragraphs (d)(1) through
(3) of this section will be available after
[date the Treasury decision adopting
these regulations as final regulations is
published in the Federal Register]. The
underlying actuarial tables reference and
explained by these publications will be
available beginning May 5, 2022, at no
charge, electronically via the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables:
(1) IRS Publication 1457, “Actuari-
al Valuations Version 4A” (2022). This
publication references tables of valuation
factors and provides examples that show
how to compute other valuation factors,
for determining the present value of annu-
ities, interests for life or a term of years,
and remainder or reversionary interests,
measured by one or two lives. These fac-
tors also may be used in the valuation of
interests in a charitable remainder annuity
trust as defined in §1.664-2 of this chap-
ter and a pooled income fund as defined
in §1.642(c)-5 of this chapter. This pub-
lication references and explains Table S
(single life remainder factors), Table R(2)
(two-life last-to-die remainder factors),
Table B (actuarial factors used in deter-
mining the present value of an interest
for a term of years), Table H (commuta-
tion factors), Table J (term certain annuity
beginning-of-interval adjustment factors),
and Table K (annuity end-of-interval ad-
justment factors). See earlier versions
of the publication, §1.642(c)-6A of this
chapter, or §20.2031-7A for Table S appli-
cable to valuation dates before [applica-
bility date of the Treasury decision adopt-
ing these regulations as final regulations].
See earlier versions of the publication for
Table R(2) applicable to valuation dates
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations]. Earlier versions of the
publication also contain earlier versions
of Table R(2). Table B, Table J, and Table
K also can be found in §20.2031-7(d)(6),
but only for interest rates from 4.2 to 14
percent, inclusive.
(2) IRS Publication 1458, “Actuari-
al Valuations Version 4B” (2022). This
publication references and explains term
certain tables and tables of one and two
life valuation factors for determining the
present value of remainder interests in a
charitable remainder unitrust as defined in
§1.664-3 of this chapter. This publication
references Table U(1) (unitrust single life
remainder factors), Table U(2) (unitrust
two-life last-to-die remainder factors),
Table D (actuarial factors used in deter-
mining the present value of a remainder
interest postponed for a term of years),
Table F (adjustment payout rate factors),
and Table Z (unitrust commutation fac-
tors). See earlier versions of the publi-
cation or §1.664-4A of this chapter for
Table U(1) applicable to valuation dates
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations]. Earlier versions of the
publication also contain earlier versions

Bulletin No. 2022–21 1135 May 23, 2022
of Table U(2). Table D also can be found
in §1.664-4(e)(6)(iii) of this chapter, but
only for adjusted payout rates from 4.2 to
14 percent, inclusive. Table F also can be
found in §1.664-4(e)(6)(iii) of this chap-
ter, but only for interest rates from 4.2 to
14 percent, inclusive.
(3) IRS Publication 1459, “Actuarial
Valuations Version 4C”
(2022). This publication references and
explains Table C, which provides factors
for making adjustments to the standard
remainder factor for valuing gifts of de-
preciable property. See §1.170A-12 of this
chapter.
(4) The publications identified in para-
graphs (d)(1) through (3) of this section
also reference Table 2010CM, the mortal-
ity component table.
(e) Use of approximation methods for
obtaining factors when the required val-
uation rate falls between two listed rates.
For certain cases, this part and IRS pub-
lications provide approximation methods
(for example, interpolation) for obtaining
factors when the required valuation rate
falls between two listed rates (such as in
the case of a pooled income fund’s rate of
return or a unitrust’s adjusted payout rate).
In general, exact methods of obtaining
the applicable factors are allowed, such
as through software using the actual rate
of return and the proper actuarial formu-
las used for the published factors at the
listed rates, provided such direct methods
are applied consistently. The actuarial for-
mula in §20.2031-7(d)(2)(ii)(B) is used to
determine the remainder factor for pooled
income funds and the actuarial formula in
§1.664-4(e)(5)(i) of this chapter is used
to determine the remainder factor for uni-
trusts. The approximation method provid-
ed in this part must be used if more exact
methods are not available.
(f) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
PART 25--GIFT TAX; GIFTS MADE
AFTER DECEMBER 31, 1954
Par. 23. The authority citation for part
25 continues to read in part as follows:
Authority: 26 U.S.C. 7805.
* * * * *
Par. 24. Section 25.2512-0 is revised to
read as follows:
§25.2512-0 Table of contents.
This section lists the section headings
that appear in the regulations under sec-
tion 2512.
§25.2512-1 Valuation of property; in
general.
§25.2512-2 Stocks and bonds.
§25.2512-3 Valuation of interests in
businesses.
§25.2512-4 Valuation of notes.
§25.2512-5 Valuation of annuities, inter-
ests for life or a term of years, and remain-
der or reversionary interests.
§25.2512-6 Valuation of certain life in-
surance and annuity contracts; valuation
of shares in an open-end investment
company.
§25.2512-7 Effect of excise tax.
§25.2512-8 Transfers for insufficient
consideration.
Actuarial Tables Applicable Before
[Applicability Date of the Treasury Deci-
sion Adopting These Regulations as Final
Regulations]
§25.2512-5A Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests trans-
ferred before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 25. Section 25.2512-5 is amended
by revising paragraphs (c), (d), and (e) to
read as follows:
§25.2512-5 Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests.
* * * * *
(c) Actuarial valuations. The present
value of annuities, interests for life or a
term of years, and remainder or reversion-
ary interests transferred by gift on or after
[applicability date of the Treasury decision
adopting these regulations as final regula-
tions], is determined under paragraph (d)
of this section. The present value of annu-
ities, interests for life or a term of years,
and remainder or reversionary interests
transferred by gift before [applicability
date of the Treasury decision adopting
these regulations as final regulations], is
determined under the following sections:
Table 1 to paragraph (c)
TransfersApplicable Regulations
AfterBefore
-01-01-5225.2512-5A(a)
12-31-5101-01-7125.2512-5A(b)
12-31-7012-01-8325.2512-5A(c)
11-30-8305-01-8925.2512-5A(d)
04-30-8905-01-9925.2512-5A(e)
04-30-9905-01-0925.2512-5A(f)
04-30-09AD25.2512-5A(g)
AD = [applicability date of the Treasury decision adopting these regulations as final regulations].

May 23, 2022 1136 Bulletin No. 2022–21
(d) Actuarial valuations on or after
[applicability date of the Treasury deci-
sion adopting these regulations as final
regulations]--(1) In general. Except as
otherwise provided in paragraph (b) of
this section and §25.7520-3(b) (relating to
exceptions to the use of prescribed tables
under certain circumstances), the fair mar-
ket value of annuities, interests for life or a
term of years, and remainder or reversion-
ary interests transferred on or after [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions], is the present value of such inter-
ests determined under paragraph (d)(2) of
this section and by using standard or spe-
cial section 7520 actuarial factors. These
factors are derived by using the actuarial
formulas provided in §20.2031-7(d)(2)
of this chapter, appropriate section 7520
interest rate, and, if applicable, the mor-
tality component for the valuation date of
the interest that is being valued. For pur-
poses of the computations described in
this section, the age of an individual is the
age of that individual at the individual’s
nearest birthday. For the convenience of
taxpayers, paragraph (d)(2) of this section
provides for published tables of factors
for specific types of interests. These pub-
lished tables provide factors for rates from
0.2 to 20 percent, inclusive, at intervals
of two-tenths of one percent. In general,
appropriate factors instead may be com-
puted directly from the actuarial formu-
las provided in §20.2031-7(d)(2) of this
chapter. In some cases, specific examples
in this part and IRS publications illustrate
approximation methods (for example, in-
terpolation) for obtaining factors when the
required valuation rate falls between two
listed rates (such as in the case of a pooled
income fund’s rate of return or a unitrust’s
adjusted payout rate). Exact methods of
obtaining the applicable actuarial factors
are allowed, such as through software us-
ing the actual rate of return and the actuar-
ial formulas provided in §20.2031-7(d)(2)
of this chapter; the approximation meth-
od provided in this part must be used if
more exact methods are not available. See
§§25.7520-1 through 25.7520-4. The fair
market value of a qualified annuity inter-
est described in section 2702(b)(1) and a
qualified unitrust interest described in sec-
tion 2702(b)(2) is the present value of such
interests determined under §25.7520-1(c).
(2) Specific interests. When the donor
transfers property in trust or otherwise
and retains an interest therein, generally,
the value of the gift is the value of the
property transferred less the value of the
donor’s retained interest. However, if the
donor transfers property after October 8,
1990, to or for the benefit of a member of
the donor’s family, the value of the gift is
the value of the property transferred less
the value of the donor’s retained interest
as determined under section 2702. If the
donor assigns or relinquishes an annuity,
an interest for life or a term of years, a re-
mainder or reversionary interest that the
donor holds by virtue of a transfer previ-
ously made by the donor or another, the
value of the gift is the value of the interest
transferred. However, see section 2519 for
a special rule in the case of the assignment
of an income interest by a person who re-
ceived the interest from a spouse.
(i) Pooled income funds and charitable
remainder trusts. The fair market value of a
remainder interest in a pooled income fund,
as defined in §1.642(c)-5 of this chapter, is
its value determined under §1.642(c)-6(e)
of this chapter (see §1.642(c)-6A of this
chapter for certain prior periods). The
fair market value of a remainder interest
in a charitable remainder annuity trust,
as described in §1.664-2(a) of this chap-
ter, is its present value determined under
§1.664-2(c) of this chapter. The fair market
value of a remainder interest in a charitable
remainder unitrust, as defined in §1.664-3
of this chapter, is its present value deter-
mined under §1.664-4(e) of this chapter.
The fair market value of a life interest or
term for years interest in a charitable re-
mainder unitrust is the fair market value of
the property as of the date of transfer less
the fair market value of the remainder inter-
est, determined under §1.664-4(e)(4) and
(5) of this chapter.
(ii) Ordinary remainder and reversion-
ary interests—(A) Remainder and rever-
sionary interests for a term of years. If
the interest to be valued is a remainder or
reversionary interest to take effect after a
definite number of years, the present value
of the interest is computed by multiplying
the value of the property by the appropri-
ate remainder factor (that corresponds to
the applicable section 7520 interest rate
and the stated term). The factor for an or-
dinary remainder interest following a term
certain may be found using the formula in
§20.2031-7(d)(2)(ii)(A) of this chapter.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in Table B. Table B 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 B is referenced
and explained in IRS Publication 1457
“Actuarial Valuations Version 4A,” which
will be available after [date the Treasury
decision adopting these regulations as fi-
nal regulations is published in the Feder-
al Register]. The remainder factors from
Table B also can be found in paragraph
(d)(6) of this section, but only for interest
rates from 4.2 to 14 percent, inclusive. For
information about obtaining special fac-
tors for other situations, see paragraph (d)
(4) of this section.
(B) Remainder and reversionary in-
terests dependent on the life of one in-
dividual. If the interest to be valued is a
remainder or reversionary interest to take
effect after the death of one individual, the
present value of the interest is computed
by multiplying the value of the property
by the appropriate remainder factor (that
corresponds to the applicable section 7520
interest rate and the age of the measuring
life of the life interest that precedes the
remainder interest). The factor for an or-
dinary remainder interest following the
death of one individual may be found by
using the formula in §20.2031-7(d)(2)(ii)
(B) of this chapter to derive factors from
the appropriate mortality table. For the
convenience of taxpayers, actuarial fac-
tors have been computed by IRS and ap-
pear in Table S. Table S will be available
beginning [DATE OF PUBLICATION
IN THE FEDERAL REGISTER], 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). Ta-
ble S is referenced and explained by IRS
Publication 1457 “Actuarial Valuations
Version 4A,” which will be available after
[date of publication of the final rule in the
Federal Register]. For information about
obtaining special factors for other situa-
tions, see paragraph (d)(4) of this section.
(iii) Ordinary interests for a term of
years and life interests. If the interest to be
valued is the right of a person to receive the

Bulletin No. 2022–21 1137 May 23, 2022
income of certain property, or to the use
of certain property, for a term of years or
for the life of one individual, the present
value of the interest is computed by mul-
tiplying the value of the property by the
appropriate actuarial factor for an interest
for a term of years or for a life interest (that
corresponds to the applicable section 7520
interest rate and the durational period). The
actuarial factor for an ordinary income in-
terest for a term certain may be found by
subtracting from 1.000000 the factor for
an ordinary remainder interest following
the same term certain that is determined
under the formula in §20.2031-7(d)(2)(ii)
(A) of this chapter. For the convenience of
taxpayers, actuarial factors have been com-
puted by IRS and appear in the “Income
Interest” column of Table B which can be
found on the IRS website at https://www.
irs.gov/retirement-plans/actuarial-tables
(or a corresponding URL as may be updat-
ed from time to time). The actuarial factor
for an ordinary income interest for the life
of one individual may be found by sub-
tracting from 1.00000 the factor for an or-
dinary remainder interest following the life
of the same individual that is determined
in §20.2031-7(d)(2)(ii)(B) of this chapter.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in the “Life Estate” column of Table
S. Table S (applicable when the valuation
date is on or after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations]) can be found
on the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. Table B
and Table S are referenced and explained
by IRS Publication 1457 “Actuarial Valu-
ations Version 4A”. See §20.2031-7A of
this chapter or earlier versions of Publica-
tion 1457 for valuation of interests before
[applicability date of the Treasury decision
adopting these regulations as final regu-
lations]. For information about obtaining
special factors for other situations, see
paragraph (d)(4) of this section.
(iv) Annuities. (A) If the interest to be
valued is the right of a person to receive an
annuity that is payable at the end of each
year for a term of years or for the life of one
individual, the present value of the interest
is computed by multiplying the aggregate
amount payable annually by the appropri-
ate annuity factor (that corresponds to the
applicable section 7520 interest rate and
annuity period). The appropriate annuity
factor for an annuity payable for a term
of years is computed by subtracting from
1.000000 the factor for an ordinary remain-
der interest following the same term cer-
tain that is determined under the formula
in §20.2031-7(d)(2)(ii)(A) of this chapter
and then dividing the result by the applica-
ble section 7520 interest rate expressed as
a number with at least four decimal places.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in the “Annuity” column of Table
B which can be found on the IRS website
at https://www.irs.gov/retirement-plans/ac-
tuarial-tables (or a corresponding URL as
may be updated from time to time). The ap-
propriate annuity factor for an annuity pay-
able for the life of one individual is comput-
ed by subtracting from 1.00000 the factor
for an ordinary remainder interest follow-
ing the life of the same individual that is
determined in §20.2031-7(d)(2)(ii)(B) of
this chapter and then dividing the result
by the applicable section 7520 interest rate
expressed as a number with four decimal
places. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in the “Annuity” column of
Table S. Table S (applicable when the val-
uation date is on or after [applicability date
of the Treasury decision adopting these
regulations as final regulations]) can be
found on the IRS website at https://www.
irs.gov/retirement-plans/actuarial-tables.
Table B and Table S are referenced and ex-
plained in IRS Publication 1457 “Actuarial
Valuations Version 4A”. See §20.2031-7A
of this chapter or earlier versions of Pub-
lication 1457 for valuation of interests
before [applicability date of the Treasury
decision adopting these regulations as final
regulations]. For information about obtain-
ing special factors for other situations, see
paragraph (d)(4) of this section.
(B) If the annuity is payable at the
end of semiannual, quarterly, monthly, or
weekly periods, the product obtained by
multiplying the annuity factor by the ag-
gregate amount payable annually then is
multiplied by the applicable adjustment
factor at the appropriate interest rate com-
ponent for payments made at the end of
the specified period. The applicable ad-
justment factor may be found using the
formula in §20.2031-7(d)(2)(iv)(B) of this
chapter. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table K. Table K, which
is referenced and explained by Publication
1457, can be found on the IRS website at
https://www.irs.gov/retirement-plans/ac-
tuarial-tables. The provisions of this para-
graph (d)(2)(iv)(B) are illustrated by the
example in paragraph (d)(2)(iv)(B)(2) of
this section.
(1) Sample factors from actuarial Table
S and Table K. For purposes of the exam-
ple in paragraph (d)(2)(iv)(B)(2) of this
section, the relevant factors from Table S
and Table K are:
Table 2 to paragraph (d)(2)(iv)(B)(1)
Factors from Table S - Based on Table 2010CM
Interest at 3.2 Percent
AgeAnnuityLife EstateRemainder
6812.25520.392170.60783
Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest RateSemi-AnnuallyQuarterlyMonthly
3.2%1.00791.01191.0146

May 23, 2022 1138 Bulletin No. 2022–21
(2) Example. On July 1 of a year after 2021, the
donor agrees to pay the annuitant the sum of $10,000
per year, payable in equal semiannual installments at
the end of each period. The semiannual installments
are to be made on each December 31st and June
30th. The annuity is payable until the annuitant’s
death. On the date of the agreement, the annuitant
is 68 years and 5 months old. The donee annuitant’s
age is treated as 68 for purposes of computing the
present value of the annuity. The section 7520 rate
on the date of the agreement is 3.2 percent. Under
Table S, the factor at 3.2 percent for determining the
present value of an annuity payable until the death
of a person aged 68 is 12.2552. The adjustment fac-
tor from Table K in the column for payments made
at the end of each semiannual period at the rate of
3.2 percent is 1.0079. The aggregate annual amount
of the annuity, $10,000, is multiplied by the factor
12.2552 and the product is multiplied by 1.0079. The
present value of the donee’s annuity is, therefore,
$123,520.16 ($10,000 × 12.2552 × 1.0079).
(C) If an annuity is payable at the be-
ginning of annual, semiannual, quarterly,
monthly, or weekly periods for a term of
years, the value of the annuity is comput-
ed by multiplying the aggregate amount
payable annually by the annuity factor de-
scribed in paragraph (d)(2)(iv)(A) of this
section; and the product so obtained then
is multiplied by the applicable adjustment
factor at the appropriate interest rate com-
ponent for payments made at the begin-
ning of specified periods. The applicable
adjustment factor may be found using the
formula in §20.2031-7(d)(2)(iv)(C) of this
chapter. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table J. Table J, which
is referenced and explained by Publication
1457, can be found on the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables. If an annuity is payable
at the beginning of annual, semiannual,
quarterly, monthly, or weekly periods for
one or more lives, the value of the annui-
ty is the sum of the first payment and the
present value of a similar annuity, the first
payment of which is not to be made until
the end of the payment period, determined
as provided in paragraph (d)(2)(iv)(B) of
this section.
(v) Annuity and unitrust interests for a
term of years or until the prior death of
an individual--(A) Annuity interests--(1)
In general. (i) The present value of an
annuity interest that is payable until the
earlier to occur of the lapse of a specific
number of years or the death of an indi-
vidual may be computed with the use of
commutation factors and an applicable
adjustment factor. The commutation fac-
tors are computed directly with the set of
formulas in Figure 1 to this paragraph (d)
(2)(v)(A)(1)(i). The prescribed mortali-
ty table is Table 2010CM as set forth in
§20.2031-7(d)(7)(ii) of this chapter, or for
periods before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations], the appropriate
table found in §20.2031-7A of this chap-
ter. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table H. Table H will
be available beginning May 5, 2022, 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). Ta-
ble H is referenced and explained by IRS
Publication 1457 “Actuarial Valuations
Version 4A,” which will be available after
[date of publication of the final rule in the
Federal Register].
Figure 1 to paragraph (d)(2)(v)(A)(1)(i)– Formulas for determining commutation factors

(ii) The applicable adjustment factor for annuities that are payable at the end of
semiannual, quarterly, monthly, or weekly periods is computed by use of the formula in
§20.2031-7(d)(2)(iv)(B) of this chapter. For the convenience of taxpayers, actuarial factors have
been computed by IRS and appear in Table K. Table K can be found on the IRS website at
https://www.irs.gov/retirement-plans/actuarial-tables. For purposes of the example in paragraph
(d)(2)(v)(A)(2) of this section, the relevant factors from Table H(2.8) and Table K are:
Table 3 to paragraph (d)(2)(v)(A)(1) (ii)
Factors from Table H(2.8)
Commutation Factors - Based on Table 2010CM
Interest Rate of 2.8 Percent
Age (x) D
x
N
x
-factor M
x
-factor
60 16,911.03 271,994.3 9,295.187
70 11,280.80 133,677.8 7,537.826

Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest Rate Semi-Annually Quarterly Monthly

Bulletin No. 2022–21 1139 May 23, 2022
(ii) The applicable adjustment factor
for annuities that are payable at the end of
semiannual, quarterly, monthly, or weekly
periods is computed by use of the formula
in §20.2031-7(d)(2)(iv)(B) of this chapter.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in Table K. Table K can be found
on the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables. For
purposes of the example in paragraph (d)
(2)(v)(A)(2) of this section, the relevant
factors from Table H(2.8) and Table K are:
Table 3 to paragraph (d)(2)(v)(A)(1)(ii)
Factors from Table H(2.8)
Commutation Factors - Based on Table 2010CM
Interest Rate of 2.8 Percent
Age (x)D
x
N
x
-factorM
x
-factor
6016,911.03271,994.39,295.187
7011,280.80133,677.87,537.826
Factors from Table K
Adjustment Factors for Annuities Payable at the End of Each Interval
Interest RateSemi-AnnuallyQuarterlyMonthly
2.8%1.00701.01041.0128
(2) Example. The donor transfers $100,000 into
a trust on January 1, 2022 and retains the right to
receive an annuity from the trust in the amount of
$10,000 per year, payable in equal semiannual in-
stallments at the end of each period. The semiannual
installments are to be made on each June 30th and
December 31st. The annuity is payable for 10 years
or until the donor’s prior death. At the time of the
transfer, the donor is 59 years and 6 months old.
The donor’s age is deemed to be 60 for purposes of
computing the present value of the retained annuity.
If the section 7520 rate for the month in which the
transfer occurred is 2.8 percent, the present value of
the donor’s retained annuity interest for the shorter
of life or term would be is $82,363.54, determined in
Figure 2 to this paragraph (d)(2)(v)(A)(2).
Figure 2 to paragraph (d)(2)(v)(A)(2) – Illustration of calculation of present value of the donor’s retained annuity interest for the
shorter of life or term
2.8% 1.0070 1.0104 1.0128

(2) Example. The donor transfers $100,000 into a trust on January 1, 2022 and retains
the right to receive an annuity from the trust in the amount of $10,000 per year, payable in equal
semiannual installments at the end of each period. The semiannual installments are to be made
on each June 30th and December 31st. The annuity is payable for 10 years or until the donor's
prior death. At the time of the transfer, the donor is 59 years and 6 months old. The donor's age
is deemed to be 60 for purposes of computing the present value of the retained annuity. If the
section 7520 rate for the month in which the transfer occurred is 2.8 percent, the present value of
the donor’s retained annuity interest for the shorter of life or term would be is $82,363.54,
determined in Figure 2 to this paragraph (d)(2)(v)(A)(2).
Figure 2 to paragraph (d)(2)(v)(A)(2) – Illustration of calculation of present value of the donor’s
retained annuity interest for the shorter of life or term

(B) Unitrust interests--( 1) In general. (i) The present value of a unitrust interest that is
payable until the earlier to occur of the lapse of a specific number of years or the death of an
individual may be computed with the use of an adjusted payout rate factor and a unitrust
commutation factor. The adjusted payout rate factor is determined by applying the formula in
§1.664-4(e)(6)(ii) of this chapter for the section 7520 interest rate applicable to the transfer. For
(B) Unitrust interests--(1) In general.
(i) The present value of a unitrust interest
that is payable until the earlier to occur of
the lapse of a specific number of years or
the death of an individual may be com-
puted with the use of an adjusted payout
rate factor and a unitrust commutation
factor. The adjusted payout rate factor is
determined by applying the formula in

May 23, 2022 1140 Bulletin No. 2022–21
§1.664-4(e)(6)(ii) of this chapter for the
section 7520 interest rate applicable to
the transfer. For the convenience of tax-
payers, actuarial factors have been com-
puted by IRS, for interest rates from 0.2
to 20 percent, inclusive, and appear in Ta-
bles F(0.2) through F(20.0). The unitrust
commutation factors are computed direct-
ly with the set of formulas in Figure 3 to
this paragraph (d)(2)(v)(B)(1)(i). For the
convenience of taxpayers, actuarial factors
have been computed by IRS and appear in
Table Z. Table F and Table Z can be found
on the IRS website at https://www.irs.gov/
retirement-plans/actuarial-tables.
Figure 3 to paragraph (d)(2)(v)(B)(1)(i) – Formulas for determining unitrust commutation factors
the convenience of taxpayers, actuarial factors have been computed by IRS, for interest rates
from 0.2 to 20 percent, inclusive, and appear in Tables F(0.2) through F(20.0). The unitrust
commutation factors are computed directly with the set of formulas in Figure 3 to this paragraph
(d)(2)(v)(B)(1)(i). For the convenience of taxpayers, actuarial factors have been computed by
IRS and appear in Table Z. Table F and Table Z can be found on the IRS website at
https://www.irs.gov/retirement-plans/actuarial-tables.
Figure 3 to paragraph (d)(2)(v)(B)(1) (i) – Formulas for determining unitrust commutation factors

(ii) For purposes of the example in paragraph (d)(2)(v)(B)(2) of this section, the relevant
factors from Table F(3.4), Table Z(4.8), and Table Z(5.0) are:
Table 4 to paragraph (d)(2)(v)(B)(1) (ii)
Factors from Table F(3.4)
Factors for Computing Adjusted Payout Rates for Unitrusts
Interest at 3.4 Percent
# of Months from Annual Valuation to First
Payout
Adjustment Factors for Payments at End of
Period
(ii) For purposes of the example in
paragraph (d)(2)(v)(B)(2) of this section,
the relevant factors from Table F(3.4), Ta-
ble Z(4.8), and Table Z(5.0) are:
Table 4 to paragraph (d)(2)(v)(B)(1)(ii)
Factors from Table F(3.4)
Factors for Computing Adjusted Payout Rates for Unitrusts
Interest at 3.4 Percent
# of Months from Annual Valuation to First PayoutAdjustment Factors for Payments at End of Period
At LeastBut Less ThanAnnualSemiannual
670.9834220.975270
Factors from Table Z(4.8)
Unitrust Commutation Factors - Based on Table 2010CM
Adjusted Payout Rate of 4.8 Percent
Age (x)
U
D
x
U
N
x
-factor
U
M
x
-factor
604,634.18958,509.091,684.151
702,491.40624,541.741,254.007

Bulletin No. 2022–21 1141 May 23, 2022
Factors from Table Z(5.0)
Unitrust Commutation Factors - Based on Table 2010CM
Adjusted Payout Rate of 5.0 Percent
Age (x)
U
D
x
U
N
x
-factor
U
M
x
-factor
604,084.82250,451.771,429.466
702,150.35620,823.441,054.386
(2) Example of interpolation. The donor who,
as of the nearest birthday, is 60 years old, transfers
$100,000 to a unitrust on January 1st of a year after
2021. The trust instrument requires that each year the
trust pay to the donor, in equal semiannual install-
ments on June 30th and December 31st, 5 percent
of the fair market value of the trust assets, valued
as of January 1st of that year, for 10 years or until
the prior death of the donor. The section 7520 rate
for the January in which the transfer occurred is 3.4
percent. Under Table F(3.4), the appropriate adjust-
ment factor is 0.975270 for semiannual payments
payable at the end of the semiannual period. The ad-
justed payout rate is 4.876 percent (5% x 0.975270).
The present value of the donor’s retained interest is
$37,419.00 determined in paragraphs (d)(2)(v)(B)(2)
(i) through (iii) of this section. Using Table Z, the
method required is to prepare two computations, one
at a payout rate of 4.8 percent, and one at 5.0 percent,
and interpolate between these two in order to get the
result at the adjusted payout rate of 4.876 percent.
As an alternative to using an interpolation method,
it also is acceptable to compute the remainder factor
directly from the root actuarial formulas using the
actual adjusted payout rate of 4.876%.
(i) Determine the terminal age, as illus-
trated in Figure 4 to this paragraph (d)(2)
(v)(B)(2)(i).
Figure 4 to paragraph (d)(2)(v)(B)(2)(i)–Illustration of determination of terminal age

(ii) Determine the Payout Interest Factor at the Table Z payout rates immediately below
and above the adjusted payout rate, as illustrated in Figure 5 to this paragraph (d)(2)(v)(B)(2)(ii).
Figure 5 to paragraph (d)(2)(v)(B)(2)(ii)–Illustration of determination of payout interest factors

(iii) Interpolate between the Payout Interest Factors at 4.8% and 5.0% to determine the
Payout Interest Factor at the adjusted rate of 4.876%, as illustrated in Figure 6 to this paragraph
(d)(2)(v)(B)(2)(iii).
Figure 6 to paragraph (d)(2)(v)(B)(2)(iii)–Illustration of interpolation
(ii) Determine the Payout Interest Fac-
tor at the Table Z payout rates immediately
below and above the adjusted payout rate, as illustrated in Figure 5 to this paragraph
(d)(2)(v)(B)(2)(ii).
Figure 5 to paragraph (d)(2)(v)(B)(2)(ii)–Illustration of determination of payout interest factors

(ii) Determine the Payout Interest Factor at the Table Z payout rates immediately below
and above the adjusted payout rate, as illustrated in Figure 5 to this paragraph (d)(2)(v)(B)(2)(ii).
Figure 5 to paragraph (d)(2)(v)(B)(2)(ii)–Illustration of determination of payout interest factors

(iii) Interpolate between the Payout Interest Factors at 4.8% and 5.0% to determine the
Payout Interest Factor at the adjusted rate of 4.876%, as illustrated in Figure 6 to this paragraph
(d)(2)(v)(B)(2)(iii).
Figure 6 to paragraph (d)(2)(v)(B)(2)(iii)–Illustration of interpolation
(iii) Interpolate between the Payout
Interest Factors at 4.8% and 5.0% to
determine the Payout Interest Factor at the
adjusted rate of 4.876%, as illustrated in
Figure 6 to this paragraph (d)(2)(v)(B)(2)
(iii).

May 23, 2022 1142 Bulletin No. 2022–21
Figure 6 to paragraph (d)(2)(v)(B)(2)(iii)–Illustration of interpolation

(3) Transitional rule. If the valuation date of a transfer of property by gift is on or after
January 1, 2021, and before [applicability date of the Treasury decision adopting these
regulations as final regulations], the fair market value of the interest transferred is determined by
using the section 7520 interest rate for the month in which the valuation date occurs (see
§§25.7520-1(b) and 25.7520-2(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. For the convenience of taxpayers, actuarial factors based on Table
2010CM appear in the proposed version of Table S, and actuarial factors based on Table
2000CM appear in the current version of Table S, which will be available as provided in
paragraph (d)(4) of this section. With respect to each individual transaction, the donor 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 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
(3) Transitional rule. If the valuation
date of a transfer of property by gift is on
or after January 1, 2021, and before [ap-
plicability date of the Treasury decision
adopting these regulations as final regula-
tions], the fair market value of the inter-
est transferred is determined by using the
section 7520 interest rate for the month
in which the valuation date occurs (see
§§25.7520-1(b) and 25.7520-2(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. For the convenience of
taxpayers, actuarial factors based on Table
2010CM appear in the proposed version
of Table S, and actuarial factors based on
Table 2000CM appear in the current ver-
sion of Table S, which will be available as
provided in paragraph (d)(4) of this sec-
tion. With respect to each individual trans-
action, the donor 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 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.
(4) Publications and actuarial compu-
tations by the Internal Revenue Service.
The factor for determining the present
value of a remainder interest that is depen-
dent on the termination of the life of one
individual may be computed by using the
formula in §20.2031-7(d)(2)(ii)(B) of this
chapter to derive factors from the appro-
priate mortality table. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table S.
The factor for determining the present
value of a remainder interest following a
term certain may be computed by using
the formula in §20.2031-7(d)(2)(ii)(A) of
this chapter. For the convenience of tax-
payers, actuarial factors have been com-
puted by IRS and appear in Table B. Ad-
justment factors for term certain annuities
payable at the beginning of each interval
may be computed by using the formula in
§20.2031-7(d)(2)(iv)(C) of this chapter.
For the convenience of taxpayers, actuari-
al factors have been computed by IRS and
appear in Table J. Adjustment factors for
annuities payable at the end of each inter-
val may be computed by using the formula
in §20.2031-7(d)(2)(iv)(B) of this chapter.
For the convenience of taxpayers, actu-
arial factors have been computed by IRS
and appear in Table K. These tables will
be available beginning May 5, 2022, 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). IRS
Publication 1457, “Actuarial Valuations
Version 4A” (2022), references and ex-
plains the factors contained in the actuar-
ial tables and also includes examples that
illustrate how to compute many special
factors for more unusual situations. This
publication will be available after [date of
publication of the final rule in the Feder-
al Register]. Table B, Table J, and Table
K also can be found in §20.2031-7(d)(6)
of this chapter, but only for interest rates

Bulletin No. 2022–21 1143 May 23, 2022
from 4.2 to 14 percent, inclusive. If a spe-
cial factor is required, the special factor
may be calculated by the taxpayer using
the actuarial formula in §20.2031-7(d)(2)
of this chapter or the taxpayer may request
a ruling to obtain the factor from the In-
ternal Revenue Service. The request for a
ruling must be accompanied by a recita-
tion of the facts including a statement of
the date of birth for each measuring life,
the date of the gift, any other applicable
dates, and a copy of the will, trust, or oth-
er relevant documents. A request for a
ruling must comply with the instructions
for requesting a ruling published period-
ically in the Internal Revenue Bulletin
(see §§601.201 and 601.601(d)(2)(ii)(b)
of this chapter and Rev. Proc. 2021-1,
2021-1 I.R.B. 1, and subsequent updates)
and must include payment of the required
user fee.
(e) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 26. The undesignated center head-
ing immediately preceding §25.2512-5A
is revised to read as follows:
Actuarial Tables Applicable Before
[Applicability Date of the Treasury Deci-
sion Adopting These Regulations]
Par. 27. Section 25.2512-5A is amend-
ed by revising the section heading and
adding paragraph (g) to read as follows:
§25.2512-5A Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests
transferred before [applicability date
of the Treasury decision adopting these
regulations as final regulations].
* * * * *
(g) Valuation of annuities, interests for
life or a term of years, and remainder or
reversionary interests transferred on or
after May 1, 2009, and before [applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations]--(1)
In general. Except as otherwise provided
in §§25.2512-5(b) and 25.7520-3(b) (per-
taining to certain limitations on the use of
prescribed tables), if the valuation date of
the transferred interest is on or after May
1, 2009, and before [applicability date
of the Treasury decision adopting these
regulations as final regulations], the fair
market value of annuities, interests for life
or a term of years, and remainder or rever-
sionary interests transferred by gift is the
present value of the interests determined
by using standard or special section 7520
actuarial factors and the valuation meth-
odology described in §25.2512-5(d). Sec-
tions 20.2031-7(d)(6) and 20.2031-7A(g)
(4) of this chapter and related sections
provide tables with standard actuarial
factors and examples that illustrate how
to use the tables to compute the pres-
ent value of ordinary annuity, life, term,
and remainder interests in property. Sec-
tions 20.2031-7(d)(6) and 20.2031-7A(g)
(4) also refer to standard and special actu-
arial factors that may be necessary to com-
pute the present value of similar interests
in more unusual fact situations. These fac-
tors and examples also generally are ap-
plicable for gift tax purposes in computing
the values of taxable gifts.
(2) Transitional rule. If the valuation
date of a transfer of property by gift is on
or after May 1, 2009, and before July 1,
2009, the fair market value of the inter-
est transferred is determined by using the
section 7520 interest rate for the month
in which the valuation date occurs (see
§§25.7520-1(b) and 25.7520-2(a)(2)) and
the appropriate actuarial tables under ei-
ther §20.2031-7A(f)(4) or (g)(4) of this
chapter, at the option of the donor. How-
ever, with respect to each individual trans-
action and with respect to all transfers
occurring on the valuation date, the donor
must consistently use the same mortality
basis with respect to each interest (in-
come, remainder, partial, etc.) in the same
property, and with respect to all transfers
occurring on the valuation date. For ex-
ample, gift and income tax charitable de-
ductions with respect to the same transfer
must be determined based on factors with
the same mortality basis, and all assets in-
cludible in the gross estate and/or estate
tax deductions claimed must be valued
based on factors with the same mortality
basis.
(3) Publications and actuarial compu-
tations by the Internal Revenue Service.
The factor for determining the present
value of a remainder interest that is de-
pendent on the termination of the life of
one individual may be computed by using
the formula in §20.2031-7(d)(2)(ii)(B)
of this chapter to derive factors from the
appropriate mortality table. For the con-
venience of taxpayers, actuarial factors
have been computed by IRS and appear
in Table S. The factor for determining the
present value of a remainder interest fol-
lowing a term certain may be computed by
using the formula in §20.2031-7(d)(2)(ii)
(A) of this chapter. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table B.
Adjustment factors for term certain an-
nuities payable at the beginning of each
interval may be computed by using the
formula in §20.2031-7(d)(2)(iv)(C) of this
chapter. For the convenience of taxpayers,
actuarial factors have been computed by
IRS and appear in Table J. Adjustment
factors for annuities payable at the end
of each interval may be computed by us-
ing the formula in §20.2031-7(d)(2)(iv)
(B) of this chapter. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in Table K.
These tables are referenced and explained
by IRS Publication 1457, “Actuarial Val-
ues Version 3A,” (2009). Publication 1457
includes examples that illustrate how to
compute many special factors for more
unusual situations. The actuarial tables are
available, at no charge, electronically via
the IRS website at https://www.irs.gov/re-
tirement-plans/actuarial-tables (or a cor-
responding URL as may be updated from
time to time). Table S also can be found
in §20.2031-7A(g)(4) of this chapter, but
only for interest rates from 0.2 to 14 per-
cent, inclusive. Table B, Table J, and Ta-
ble K also can be found in §20.2031-7(d)
(6) of this chapter, but only for interest
rates from 4.2 to 14 percent, inclusive. If
a special factor is required in the case of a
completed gift, the special factor may be
calculated by the donor using the actuar-
ial formulas in §20.2031-7(d)(2) of this
chapter or the donor may request a rul-
ing to obtain the factor from the Internal
Revenue Service. The request for a ruling
must be accompanied by a recitation of
the facts including a statement of the date
of birth for each measuring life, the date
of the gift, any other applicable dates, and
a copy of the will, trust, or other relevant
documents. A request for a ruling must
comply with the instructions for request-
ing a ruling published periodically in the
Internal Revenue Bulletin (see §§601.201
and 601.601(d)(2)(ii)(b) of this chapter)

May 23, 2022 1144 Bulletin No. 2022–21
and must include payment of the required
user fee.
(4) Applicability dates. Paragraphs (g)
(1) through (3) of this section apply on and
after May 1, 2009, and before [applicabil-
ity date of the Treasury decision adopting
these regulations as final regulations].
Par. 28. Section 25.2522(c)-3 is amend-
ed by:
1. Designating Examples 1 through 3
of paragraph (d)(2)(iv) as paragraphs (d)
(2)(iv)(A) through (C), respectively.
2. Revising the headings for newly des-
ignated paragraphs (d)(2)(iv)(A) and (B),
newly designated paragraph (d)(2)(iv)(C),
and paragraph (e).
3. Adding paragraph (f).
The revisions and addition read as
follows:
§25.2522(c)-3 Transfers not exclusively
for charitable, etc., purposes in the case
of gifts made after July 31, 1969.
* * * * *
(d) * * *
(2) * * *
(iv) * * *
(A) Example 1. * * *
(B) Example 2. * * *
(C) Example 3--(1) Factors. The appropriate
annuity factor for an annuity payable for a term of
years is computed by subtracting from 1.000000 the
factor for an ordinary remainder interest following
the same term certain that is determined under the
formula in §20.2031-7(d)(2)(ii)(A) of this chapter
and then dividing the result by the applicable sec-
tion 7520 interest rate expressed as a number with
at least four decimal places. For the convenience of
taxpayers, actuarial factors have been computed by
IRS and appear in the “Annuity” column of Table B.
The actuarial commutation factors can be computed
directly by using the formulas in §25.2512-5(d)(2)
(v)(A)(1), the section 7520 rate, and Table 2010CM
as set forth in §20.2031-7(d)(7)(ii) of this chapter.
For the convenience of taxpayers, actuarial factors
have been computed by IRS and appear in Table H.
Table B and Table H can be found on the IRS website
at https://www.irs.gov/retirement-plans/actuarial-ta-
bles (or a corresponding URL as may be updated
from time to time). For purposes of the example in
paragraph (d)(2)(iv)(C)(2) of this section, the rele-
vant factors from Table B and Table H are:
Table 1 to paragraph (d)(2)(iv)(C)(1)
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 2.8 Percent
YearsAnnuityIncome InterestRemainder
108.61790.2413020.758698
Factors from Table H(2.8)
Commutation Factors - Based on Table 2010CM
Interest Rate of 2.8 Percent
Age (x)D
x
N
x
-factorM
x
-factor
6016,911.03271,994.39,295.187
7011,280.80133,677.87,537.826
(2) Application. In a year after 2021, D
transfers $65,000 in trust with the require-
ment that a guaranteed annuity interest
(as defined in paragraph (c)(2)(vi) of this
section) of $5,000 a year, payable annu-
ally at the end of each year, be paid to Y
Charity for a period of 10 years and that
a guaranteed annuity interest (as defined
in paragraph (c)(2)(vi) of this section) of
$5,000 a year, payable annually at the end
of each year, be paid to W, D’s wife, aged
60, for 10 years or until her prior death.
The annuities are to be paid simultaneous-
ly, and the remainder is to be paid to D’s
children. The section 7520 interest rate for
the date of transfer is 2.8 percent, and the
taxpayer elects not to use the interest rate
from either of the two preceding months.
The fair market value of the private an-
nuity is $40,895.50 ($5,000 × 8.1791), as
determined pursuant to §25.2512-5(d)(2)
(v)(A) and by the use of factors derived
from Table H and illustrated in paragraph
(d)(2)(iv)(C)(3) of this section. The fair
market value of the charitable annuity is
$43,089.50 ($5,000 × 8.6179), determined
using the annuity factor from Table B. It
is not evident from the governing instru-
ment of the trust or from local law that
the trustee would be required to apportion
the trust fund between the wife and char-
ity in the event the fund were insufficient
to pay both annuities in a given year. Ac-
cordingly, the deduction with respect to
the charitable annuity will be limited to
$24,104.50 ($65,000 less $40,895.50 [the
value of the private annuity]), which is the
minimum amount it is evident the charity
will receive.
(3) In paragraph (d)(2)(iv)(C)(2) of this
section, the actuarial factor for determin-
ing the value of the private annuity is de-
rived by the use of factors involving one
life and a term of years. The factor is de-
termined as illustrated in Figure 1 to this
paragraph (d)(2)(iv)(C)(3).

Bulletin No. 2022–21 1145 May 23, 2022
Figure 1 to paragraph (d)(2)(iv)(C)(3) – Illustration of calculation of annuity factor for shorter of term or life
private annuity]), which is the minimum amount it is evident the charity will receive.
(3) In paragraph (d)(2)(iv)(C)(2) of this section, the actuarial factor for determining the
value of the private annuity is derived by the use of factors involving one life and a term of
years. The factor is determined as illustrated in Figure 1 to this paragraph (d)(2)(iv)(C)(3).
Figure 1 to paragraph (d)(2)(iv)(C)(3) – Illustration of calculation of annuity factor for shorter of
term or life

* * * * *
(e) Guaranteed annuity and unitrust interests reformed as an interest for a term of years--
(1) In general. The rule in paragraphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this section that
guaranteed annuity interests or unitrust interests, respectively, may be payable for a specified
term of years or for the life or lives of only certain individuals applies to transfers made on or
after April 4, 2000. If a transfer is made on or after April 4, 2000, that uses an individual other
than one permitted in paragraphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of this section, the interest may
be reformed into a lead interest payable for a specified term of years. The term of years is
determined by taking the factor for valuing the annuity or unitrust interest for the named
individual measuring life and identifying the term of years (rounded up to the next whole year)
that corresponds to the equivalent term of years factor for an annuity or unitrust interest. See
paragraph (e)(4) of this section for an example.
(2) Judicial and non-judicial reformations. A judicial reformation must be commenced
prior to October 15th of the year following the year in which the transfer is made and must be
* * * * *
(e) Guaranteed annuity and unitrust
interests reformed as an interest for a term
of years--(1) In general. The rule in para-
graphs (c)(2)(vi)(a) and (c)(2)(vii)(a) of
this section that guaranteed annuity inter-
ests or unitrust interests, respectively, may
be payable for a specified term of years or
for the life or lives of only certain individ-
uals applies to transfers made on or after
April 4, 2000. If a transfer is made on or
after April 4, 2000, that uses an individual
other than one permitted in paragraphs (c)
(2)(vi)(a) and (c)(2)(vii)(a) of this section,
the interest may be reformed into a lead
interest payable for a specified term of
years. The term of years is determined by
taking the factor for valuing the annuity or
unitrust interest for the named individual
measuring life and identifying the term of
years (rounded up to the next whole year)
that corresponds to the equivalent term of
years factor for an annuity or unitrust in-
terest. See paragraph (e)(4) of this section
for an example.
(2) Judicial and non-judicial reforma-
tions. A judicial reformation must be com-
menced prior to October 15th of the year
following the year in which the transfer
is made and must be completed within a
reasonable time after it is commenced. A
non-judicial reformation is permitted if
effective under state law, provided it is
completed by the date on which a judicial
reformation must be commenced. In the
alternative, if a court, in a proceeding that
is commenced on or before July 5, 2001,
declares any transfer, made on or after
April 4, 2000, and on or before March 6,
2001, null and void ab initio, the Internal
Revenue Service will treat such transfers
in a manner similar to that described in
section 2055(e)(3)(J).
(3) Sample factors from actuarial Ta-
ble B and Table S. The appropriate an-
nuity factor for an annuity payable for a
term of years is computed by subtracting
from 1.000000 the factor for an ordinary
remainder interest following the same
term certain that is determined under the
formula in §20.2031-7(d)(2)(ii)(A) of
this chapter and then dividing the result
by the applicable section 7520 interest
rate expressed as a number with at least
four decimal places. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in the “An-
nuity” column of Table B. The appropriate
annuity factor for an annuity payable for
the life of one individual is computed by
subtracting from 1.00000 the factor for an
ordinary remainder interest following the
life of the same individual that is deter-
mined under the formula in §20.2031-7(d)
(2)(ii)(B) of this chapter and then dividing
the result by the applicable section 7520
interest rate expressed as a number with
four decimal places. For the convenience
of taxpayers, actuarial factors have been
computed by IRS and appear in the “An-
nuity” column of Table S. Table B and
Table S can be found on the IRS website
at https://www.irs.gov/retirement-plans/
actuarial-tables. For purposes of the ex-
ample in paragraph (e)(4) of this section,
the relevant factors from Table B and Ta-
ble S are:
Table 2 to paragraph (e)(3)
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 2.4 Percent
YearsAnnuityIncome InterestRemainder
3824.74710.5939290.406071
3925.14360.6034470.396553

May 23, 2022 1146 Bulletin No. 2022–21
Factors from Table S - Based on Table 2010CM
Interest at 2.4 Percent
AgeAnnuityLife EstateRemainder
4024.90630.597750.40225
(4) Example. An annuity interest payable for the
life of an individual age 40 at the time of the trans-
fer that occurs on or after [applicability date of the
Treasury decision adopting these regulations as final
regulations] assuming an interest rate of 2.4 percent
under section 7520, has an annuity factor reported in
Table S of 24.9063. Based on Table B at 2.4 percent,
the factor 24.9063 corresponds to a term of years
between 38 and 39 years. Accordingly, the annuity
interest must be reformed into an interest payable
for a term of 39 years. (To determine the value of a
charitable remainder interest payable after this an-
nuity interest, the taxpayer then must satisfy the test
illustrated in §25.7520-3(b)(2)(v)(E).)
(f) Applicability date. This section
applies only to gifts made after July 31,
1969.
Par. 29. Section 25.7520-1 is amended
by revising paragraphs (a)(1) and (2), (b)
(2), (c), and (d) and adding paragraphs (e)
and (f) to read as follows:
§25.7520-1 Valuation of annuities,
interests for life or a term of years, and
remainder or reversionary interests.
(a) * * *(1) Except as otherwise pro-
vided in this section and in §25.7520-3(b)
(relating to exceptions to the use of pre-
scribed tables under certain circumstanc-
es), in the case of certain gifts after April
30, 1989, the fair market value of annu-
ities, interests for life or a term of years
(including unitrust interests), and remain-
der or reversionary interests is their pres-
ent value determined under this section.
See §20.2031-7(d) of this chapter (and,
for periods prior to [applicability date of
the Treasury decision adopting these regu-
lations as final regulations], §20.2031-7A
of this chapter) for the computation of the
value of annuities, interests for life or a
term of years, and remainder or reversion-
ary interests, other than interests described
in paragraphs (a)(2) and (3) of this section.
(2) In the case of a gift to a pooled in-
come fund on or after [applicability date
of the Treasury decision adopting these
regulations as final regulations], see
§1.642(c)-6(e) of this chapter (or, for peri-
ods prior to [applicability date of the Trea-
sury decision adopting these regulations
as final regulations], §1.642(c)-6A of this
chapter) with respect to the valuation of
the remainder interest.
* * * * *
(b) * * *
(2) Mortality component. The mortal-
ity component reflects the mortality data
most recently available from the United
States census. As new mortality data be-
comes available after each decennial cen-
sus, the mortality component described
in this section will be revised and the re-
vised mortality component tables will be
published in the IRS publications at that
time. For gifts with valuation dates on or
after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations], the mortality component
table (Table 2010CM) is in §20.2031-7(d)
(7)(ii) of this chapter, and is referenced by
IRS Publication 1457, “Actuarial Valu-
ations Version 4A,” and can be found on
the IRS website at https://www.irs.gov/re-
tirement-plans/actuarial-tables (or a cor-
responding URL as may be updated from
time to time). See §20.2031-7A of this
chapter for mortality component tables
applicable to gifts for which the valuation
date falls before [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
(c) Actuarial factors. The present
value on the valuation date of an annui-
ty, an interest for life or a term of years,
and a remainder or reversionary interest
is computed by using the section 7520
interest rate component that is described
in paragraph (b)(1) of this section and the
mortality component that is described in
paragraph (b)(2) of this section. Actuarial
factors for determining these present val-
ues may be calculated using the formulas
in §20.2031-7(d)(2) of this chapter. For
the convenience of taxpayers, the IRS
has computed actuarial factors and dis-
played them on tables that are referenced
and explained by publications of the In-
ternal Revenue Service. If a special factor
is required in order to value an interest,
the special factor may be calculated by
the taxpayer using the actuarial formu-
las in §20.2031-7(d)(2) of this chapter or
the taxpayer may request a ruling to ob-
tain the factor from the Internal Revenue
Service. The request for a ruling must be
accompanied by a recitation of the facts,
including the date of birth for each mea-
suring life and copies of relevant instru-
ments. A request for a ruling must comply
with the instructions for requesting a rul-
ing published periodically in the Internal
Revenue Bulletin (see Rev. Proc. 2021-1,
2021-1 I.R.B. 1, and subsequent updates,
and §§ 601.201 and 601.601(d)(2)(ii)(b)
of this chapter) and must include payment
of the required user fee.
(d) IRS publications referencing and
explaining actuarial tables with rates from
0.2 to 20 percent, inclusive, at intervals of
two-tenths of one percent, for valuation
dates on or after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations]. The publica-
tions listed in paragraphs (d)(1) through
(3) of this section will be available after
[date of publication of the final rule in the
Federal Register]. The underlying actu-
arial tables referenced and explained by
these publications will be available begin-
ning May 5, 2022, at no charge, electron-
ically via the IRS website at https://www.
irs.gov/retirement-plans/actuarial-tables:
(1) IRS Publication 1457, “Actuari-
al Valuations Version 4A” (2022). This
publication references tables of valuation
factors and provides examples that show
how to compute other valuation factors,
for determining the present value of annu-
ities, interests for life or a term of years,
and remainder or reversionary interests,
measured by one or two lives. These fac-
tors may also be used in the valuation of
interests in a charitable remainder an-
nuity trust as defined in §1.664-2 of this
chapter and a pooled income fund as de-
fined in §1.642(c)-5 of this chapter. This
publication references and explains Ta-
ble S (single life remainder factors), Ta-
ble R(2) (two-life last-to-die remainder
factors), Table B (actuarial factors used in

Bulletin No. 2022–21 1147 May 23, 2022
determining the present value of an inter-
est for a term of years), Table H (commuta-
tion factors), Table J (term certain annuity
beginning-of-interval adjustment factors),
and Table K (annuity end-of-interval ad-
justment factors). See earlier versions
of the publication, §1.642(c)-6A of this
chapter, or §20.2031-7A of this chapter
for Table S applicable to valuation dates
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations]. Earlier versions of the
publication also contain earlier versions
of Table R(2). Table B, Table J, and Table
K also can be found in §20.2031-7(d)(6)
of this chapter, but only for interest rates
from 4.2 to 14 percent, inclusive.
(2) IRS Publication 1458, “Actuari-
al Valuations Version 4B” (2022). This
publication references and explains term
certain tables and tables of one and two
life valuation factors for determining the
present value of remainder interests in a
charitable remainder unitrust as defined in
§1.664-3 of this chapter. This publication
references Table U(1) (unitrust single life
remainder factors), Table U(2) (unitrust
two-life last-to-die remainder factors),
Table D (actuarial factors used in deter-
mining the present value of a remainder
interest postponed for a term of years),
Table F (adjustment payout rate factors),
and Table Z (unitrust commutation fac-
tors). See earlier versions of the publi-
cation or §1.664-4A of this chapter for
Table U(1) applicable to valuation dates
before [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations]. Earlier versions of the
publication also contain earlier versions
of Table U(2). Table D also can be found
in §1.664-4(e)(6)(iii) of this chapter, but
only for adjusted payout rates from 4.2 to
14 percent, inclusive. Table F also can be
found in §1.664-4(e)(6)(iii) of this chap-
ter, but only for interest rates from 4.2 to
14 percent, inclusive.
(3) IRS Publication 1459, “Actuarial
Valuations Version 4C” (2022). This pub-
lication references and explains Table C,
which provides factors for making adjust-
ments to the standard remainder factor for
valuing gifts of depreciable property. See
§1.170A-12 of this chapter.
(4) The publications identified in para-
graphs (d)(1) through (3) of this section
also reference Table 2010CM, the mortal-
ity component table.
(e) Use of approximation methods for
obtaining factors when the required val-
uation rate falls between two listed rates.
For certain cases, this part and IRS pub-
lications provide approximation methods
(for example, interpolation) for obtaining
factors when the required valuation rate
falls between two listed rates (such as in
the case of a pooled income fund’s rate of
return or a unitrust’s adjusted payout rate).
In general, exact methods of obtaining
the applicable factors are allowed, such
as through software using the actual rate
of return and the proper actuarial formula,
provided such direct methods are applied
consistently. The actuarial formula in
§20.2031-7(d)(2)(ii)(B) of this chapter is
used to determine the remainder factor for
pooled income funds and the actuarial for-
mula in §1.664-4(e)(5)(i) of this chapter
is used to determine the remainder factor
for unitrusts. The approximation method
provided in this part must be used if more
exact methods are not available.
(f) Applicability date. This section ap-
plies on and after [applicability date of the
Treasury decision adopting these regula-
tions as final regulations].
Par. 30. Section 25.7520-3 is amended
by:
1. Designating Examples 1 through 5
of paragraph (b)(2)(v) as paragraphs (b)
(2)(v)(A) through (E), respectively.
2. Revising the heading of newly des-
ignated paragraphs (b)(2)(v)(A).
3. In newly designated paragraph (b)
(2)(v)(B):
i. Revising the heading.
ii. Removing “Example 1” and “this
paragraph” and adding in their places
“paragraph (b)(2)(v)(A) of this section
(Example 1)” and “this paragraph (b)(2)
(v)(B)”, respectively.
4. Revising the heading for newly des-
ignated paragraph (b)(2)(v)(C).
5. In newly designated paragraph (b)
(2)(v)(D):
i. Revising the heading.
ii. Removing “Example 3” and adding
“paragraph (b)(2)(v)(C) of this section
(Example 3)” in its place.
6. Revising newly designated para-
graph (b)(2)(v)(E) and paragraphs (b)(4)
and (c).
The revisions read as follows:
§25.7520-3 Limitation on the application
of section 7520.
* * * * *
(b) * * *
(2) * * *
(v) * * *
(A) Example 1. Unproductive property. * * *
(B) Example 2. Beneficiary’s right to make trust
productive. * * *
(C) Example 3. Annuity trust funded with unpro-
ductive property. * * *
(D) Example 4. Unitrust funded with unproduc-
tive property. * * *
(E) Example 5: Eroding corpus in an annuity
payable from a trust or other limited fund. (1) The
present value of an annuity interest (and any other
interest dependent on the present value of an an-
nuity), when the annuity is paid from an eroding
and limited fund, is determined by actuarial factors
reflecting the term certain period to the exhaustion
of the fund, as shown in Table 1 to this paragraph
(b)(2)(v)(E)(1). The period to exhaustion is deter-
mined using annuity factors. The appropriate an-
nuity factors for an annuity payable for a term of
years is computed by subtracting from 1.000000
the factor for an ordinary remainder interest fol-
lowing the same term certain that is determined
under the formula in §20.2031-7(d)(2)(ii)(A) of
this chapter and then dividing the result by the ap-
plicable section 7520 interest rate expressed as a
number with at least four decimal places. For the
convenience of taxpayers, actuarial factors have
been computed by IRS and appear in the “Annuity”
column of Table B. If the annuity is for life (or for
a period depending in part on life) and the period
to exhaustion is shorter than the possible life peri-
od, actuarial commutation factors may be used in
determining the present value. The actuarial com-
mutation factors can be computed directly by us-
ing the formulas in §25.2512-5(d)(2)(v)(A)(1), the
section 7520 rate, and Table 2010CM as set forth
in §20.2031-7(d)(7)(ii) of this chapter. For the con-
venience of taxpayers, actuarial factors have been
computed by IRS and appear in Table H. Table B
and Table H can be found on the IRS website at
https://www.irs.gov/retirement-plans/actuarial-ta-
bles (or a corresponding URL as may be updated
from time to time). After determining the point of
exhaustion of funds, the approximation method for
determining the present value of annuity payments
so limited by exhaustion in the example in Table
1 to this paragraph (b)(2)(v)(E)(1) is to be used if
a more exact method (for example, computing the
year-by-year present value of each payment until
the fund is exhausted) is not used. For purposes of
this example, the relevant factors from Table B and
Table H(4.4) are:

May 23, 2022 1148 Bulletin No. 2022–21
Table 1 to paragraph (b)(2)(v)(E)(1)
Factors from Table B
Annuity, Income, and Remainder Interests for a Term Certain
Interest at 4.4 Percent
YearsAnnuityIncome InterestRemainder
139.74230.4286610.571339
1410.28960.4527410.547259
5020.08780.8838620.116138
Factors from Table H(4.4)
Commutation Factors - Based on Table 2010CM
Interest Rate of 4.4 Percent
Age (x)D
x
N
x
-factorM
x
-factor
606,694.63690,259.342,723.225
733,151.22829,432.251,856.209
742,941.07526,452.501,777.165
(2) The donor, who is age 60 and in
normal health, transfers property worth
$1,000,000 to a trust on or after [appli-
cability date of the Treasury decision
adopting these regulations as final reg-
ulations]. The trust will pay a 10 per-
cent ($100,000 per year) annuity to a
charitable organization for the life of
the donor, payable annually at the end
of each period, and the remainder then
will be distributed to the donor’s child.
The section 7520 rate for the month of
the transfer is 4.4 percent. First, it is
necessary to determine whether the an-
nuity may exhaust the corpus before all
annuity payments are made. Because it
is assumed under the prescribed mortal-
ity component, Table 2010CM, that any
measuring life may survive until age
110, any life annuity could require pay-
ments until the measuring life reaches
age 110. The determination of whether
the annuity may exhaust the corpus be-
fore the annuity payments terminate is
computed with values from Table B as
illustrated in Figure 1 to this paragraph
(b)(2)(v)(E)(2).
Figure 1 to paragraph (b)(2)(v)(E)(2) – Illustration of determining present value of term certain annuity
Figure 1 to paragraph (b)(2)(v)(E)(2) – Illustration of determining present value of term certain
annuity

(3) Because the present value of an annuity for a term of 50 years exceeds the corpus, the
annuity may exhaust the trust before all payments are made. Consequently, the annuity must be
valued as an annuity payable for a term of years or until the prior death of the annuitant, with the
term of years determined by when the fund will be exhausted by the annuity payments, assuming
earnings at the section 7520 rate of 4.4 percent.
(4) If an annuity of $100,000 payable at the end of each year for a period had an annuity
factor of 10.0, it would have a present value exactly equal to the principal available to pay the
annuity over the term. The annuity factor for 13 years at 4.4 percent in Table B is 9.7423 and the
annuity factor for 14 years at 4.4 percent is 10.2896. Thus, it is determined that the $1,000,000
initial transfer will be sufficient to make 13 annual payments of $100,000, but not to make the
entire 14th payment. The present value of an annuity of $100,000 payable at the end of each
year for 13 years certain is $100,000 times 9.7423 or $974,230. The remaining amount is
$25,770. Of the initial transfer amount, $25,770 is n ot needed to make payments for 13 years, so
this amount, as accumulated for 14 years, will be available for the final payment. The 14-year
accumulation factor is 1.8273 ((1 + 0.044)
14
= 1.8273), so the amount available in 14 years is
$25,770 times 1.8273 or $47,089.52. Therefore, for purposes of this present value
determination, the annuity obligation is treated as being composed of two distinct annuity
components. The two annuity components taken together must equal the total annual amount of
$100,000. The first annuity component is the exact amount that the trust will have available for
(3) Because the present value of an
annuity for a term of 50 years exceeds
the corpus, the annuity may exhaust the
trust before all payments are made. Con-
sequently, the annuity must be valued as
an annuity payable for a term of years or
until the prior death of the annuitant, with
the term of years determined by when the
fund will be exhausted by the annuity pay-
ments, assuming earnings at the section
7520 rate of 4.4 percent.
(4) If an annuity of $100,000 pay-
able at the end of each year for a period
had an annuity factor of 10.0, it would
have a present value exactly equal to the
principal available to pay the annuity
over the term. The annuity factor for 13
years at 4.4 percent in Table B is 9.7423
and the annuity factor for 14 years at
4.4 percent is 10.2896. Thus, it is deter-
mined that the $1,000,000 initial trans-
fer will be sufficient to make 13 annual
payments of $100,000, but not to make
the entire 14th payment. The present val-
ue of an annuity of $100,000 payable at
the end of each year for 13 years certain
is $100,000 times 9.7423 or $974,230.
The remaining amount is $25,770. Of
the initial transfer amount, $25,770 is not
needed to make payments for 13 years,
so this amount, as accumulated for 14
years, will be available for the final pay-
ment. The 14-year accumulation factor
is 1.8273 ((1 + 0.044)
14
= 1.8273), so the
amount available in 14 years is $25,770

Bulletin No. 2022–21 1149 May 23, 2022
times 1.8273 or $47,089.52. Therefore,
for purposes of this present value deter-
mination, the annuity obligation is treated
as being composed of two distinct annui-
ty components. The two annuity compo-
nents taken together must equal the total
annual amount of $100,000. The first an-
nuity component is the exact amount that
the trust will have available for the final
payment, $47,089.52. The second annuity
component then must be $100,000 minus
$47,089.52, or $52,910.48. Specifically,
the initial corpus will be able to make pay-
ments of $52,910.48 per year for 13 years
plus payments of $47,089.52 per year for
14 years. The total annuity is valued by
adding the present value of the two sepa-
rate temporary component annuities.
(5) The actuarial factor for deter-
mining the value of the annuity of
$52,910.48 per year payable for 13
years or until the prior death of a person
aged 60 is derived by the use of factors
involving one life and a term of years,
derived from Table H. The factor is de-
termined as illustrated in Figure 2 to this
paragraph (b)(2)(v)(E)(5).
Figure 2 to paragraph (b)(2)(v)(E)(5) – Illustration of determining annuity factor for shorter of life or 13 years
the final payment, $47,089.52. The second annuity component then must be $100,000 minus
$47,089.52, or $52,910.48. Specifically, the initial corpus will be able to make payments of
$52,910.48 per year for 13 years plus payments of $47,089.52 per year for 14 years. The total
annuity is valued by adding the present value of the two separate temporary component
annuities.
(5) The actuarial factor for determining the value of the annuity of $52,910.48 per year
payable for 13 years or until the prior death of a person aged 60 is derived by the use of factors
involving one life and a term of years, derived from Table H. The factor is determined as
illustrated in Figure 2 to this paragraph (b)(2)(v)(E)(5).
Figure 2 to paragraph (b)(2)(v)(E)(5) – Illustration of determining annuity factor for shorter of
life or 13 years

(6) The actuarial factor for determining the value of the annuity $47,089.52 per year
payable for 14 years or until the prior death of a person aged 60 is derived by the use of factors
involving one life and a term of years, derived from Table H. The factor is determined as
illustrated in Figure 3 to this paragraph (b)(2)(v)(E)(6).
Figure 3 to paragraph (b)(2)(v)(E)(6) – Illustration of determining annuity factor for shorter of
life or 14 years
(6) The actuarial factor for determining
the value of the annuity $47,089.52 per
year payable for 14 years or until the prior
death of a person aged 60 is derived by
the use of factors involving one life and a
term of years, derived from Table H. The
factor is determined as illustrated in Fig-
ure 3 to this paragraph (b)(2)(v)(E)(6).
Figure 3 to paragraph (b)(2)(v)(E)(6) – Illustration of determining annuity factor for shorter of life or 14 years

(7) Based on the calculations of paragraph (b)(2)(v)(E)(5) of this section, the present
value of an annuity of $52,910.48 per year payable for 13 years or until the prior death of a
person aged 60 is $480,739.33 ($52,910.48 × 9.0859). Based on the calculations of paragraph
(b)(2)(v)(E)(6) of this section, the present value of an annuity of $47,089.52 per year payable for
14 years or until the prior death of a person aged 60 is $448,810.22 ($47,089.52 × 9.5310).
Thus, the present value of the charitable annuity interest is the sum of the two component
annuities, $929,549.55 ($480,739.33 + $448,810.22).
* * * * *

(4) Example - terminal illness--(i) Sample factors from actuarial Table S. The provisions
of paragraph (b)(3) of this section are illustrated by the example in paragraph (b)(4)(ii) of this
section. The appropriate annuity factor for an annuity payable for the life of one individual is
computed by subtracting from 1.00000 the factor for an ordinary remainder interest following the
life of the same individual that is determined under the formula in §20.2031-7(d)(2)(ii)(B) of this
chapter and then dividing the result by the applicable section 7520 interest rate expressed as a
number with four decimal places. For the convenience of taxpayers, actuarial factors have been
computed by IRS and appear in the “Annuity” column of Table S. Table S can be found on the
IRS website at https://www.irs.gov/retirement-plans/actuarial-tables. For purposes of the
example in paragraph (b)(4)(ii) of this section, the relevant factor from Table S is:
Table 2 to paragraph (b)(4)(i)

May 23, 2022 1150 Bulletin No. 2022–21
(7) Based on the calculations of
paragraph (b)(2)(v)(E)(5) of this sec-
tion, the present value of an annuity of
$52,910.48 per year payable for 13 years
or until the prior death of a person aged
60 is $480,739.33 ($52,910.48 × 9.0859).
Based on the calculations of paragraph
(b)(2)(v)(E)(6) of this section, the pres-
ent value of an annuity of $47,089.52 per
year payable for 14 years or until the prior
death of a person aged 60 is $448,810.22
($47,089.52 × 9.5310). Thus, the pres-
ent value of the charitable annuity in-
terest is the sum of the two component
annuities, $929,549.55 ($480,739.33 +
$448,810.22).
* * * * *
(4) Example - terminal illness--(i) Sample factors
from actuarial Table S. The provisions of paragraph
(b)(3) of this section are illustrated by the example
in paragraph (b)(4)(ii) of this section. The appropri-
ate annuity factor for an annuity payable for the life
of one individual is computed by subtracting from
1.00000 the factor for an ordinary remainder interest
following the life of the same individual that is de-
termined under the formula in §20.2031-7(d)(2)(ii)
(B) of this chapter and then dividing the result by
the applicable section 7520 interest rate expressed as
a number with four decimal places. For the conve-
nience of taxpayers, actuarial factors have been com-
puted by IRS and appear in the “Annuity” column
of Table S. Table S can be found on the IRS website
at https://www.irs.gov/retirement-plans/actuarial-ta-
bles. For purposes of the example in paragraph (b)(4)
(ii) of this section, the relevant factor from Table S is:
Table 2 to paragraph (b)(4)(i)
Factors from Table S - Based on Table 2010CM
Interest at 4.4 Percent
AgeAnnuityLife EstateRemainder
758.64730.380480.61952
(ii) Example of donor with terminal illness. The
donor transfers property worth $1,000,000 to a child
on or after [applicability date of the Treasury deci-
sion adopting these regulations as final regulations],
in exchange for the child’s promise to pay the donor
$80,000 per year for the donor’s life, payable annu-
ally at the end of each period. The section 7520 in-
terest rate for the month of the transfer is 4.4 percent.
The donor is age 75 but has been diagnosed with an
incurable illness and has at least a 50 percent prob-
ability of dying within 1 year. Under Table S, the
annuity factor at 4.4 percent for a person age 75 in
normal health is 8.6473. Thus, if the donor were not
terminally ill, the present value of the annuity would
be $691,784 ($80,000 × 8.6473). Assuming the pre-
sumption provided in paragraph (b)(3) of this section
does not apply, because there is at least a 50 percent
probability that the donor will die within 1 year, the
standard section 7520 annuity factor may not be used
to determine the present value of the donor’s annu-
ity interest. Instead, a special section 7520 annuity
factor must be computed that takes into account the
projection of the donor’s actual life expectancy.
* * * * *
(c) Applicability dates. Section
25.7520-3(a) is applicable as of May 1,
1989. The provisions of paragraph (b) of
this section, except paragraphs (b)(2)(v)
(E) and (b)(4) of this section, are applica-
ble to gifts made after December 13, 1995.
Paragraphs (b)(2)(v)(E) and (b)(4) of this
section are applicable to gifts made on or
after [applicability date of the Treasury
decision adopting these regulations as fi-
nal regulations].
Douglas W. O’Donnell,
Deputy Commissioner for Services
and Enforcement.
(Filed by the Office of the Federal Register on
May 4, 2022, 8:45 a.m., and published in the issue of
the Federal Register for May 5, 2022, 87 F.R. 26806)

Bulletin No. 2022–21 i May 23, 2022
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion. It
is not used where a position in a prior rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cas-
es in litigation, or the outcome of a Ser-
vice study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI
—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

May 23, 2022 ii Bulletin No. 2022–21
Numerical Finding List
1
Bulletin 2022–21
Announcements:
2022-3, 2022-8 I.R.B. 788
2022-4, 2022-9 I.R.B. 789
2022-5, 2022-11 I.R.B. 825
2022-6, 2022-13 I.R.B. 934
2022-7, 2022-15 I.R.B. 946
2022-8, 2022-19 I.R.B. 1056
AOD:
2022-1, 2022-06 I.R.B. 466
2022-2, 2022-12 I.R.B. 903
Notices:
2022-1, 2022-02 I.R.B. 304
2022-2, 2022-02 I.R.B. 304
2022-3, 2022-02 I.R.B. 308
2022-4, 2022-02 I.R.B. 309
2022-5, 2022-05 I.R.B. 457
2022-6, 2022-05 I.R.B. 460
2022-7, 2022-06 I.R.B. 469
2022-8, 2022-07 I.R.B. 491
2022-9, 2022-10 I.R.B. 811
2022-10, 2022-10 I.R.B. 815
2022-12, 2022-12 I.R.B. 906
2022-11, 2022-14 I.R.B. 939
2022-13, 2022-14 I.R.B. 940
2022-14, 2022-14 I.R.B. 941
2022-15, 2022-18 I.R.B. 1043
2022-16, 2022-18 I.R.B. 1044
2022-17, 2022-18 I.R.B. 1048
2022-18, 2022-18 I.R.B. 1048
2022-19, 2022-18 I.R.B. 1050
2022-21, 2022-20 I.R.B. 1057
2022-22, 2022-20 I.R.B. 1057
2022-23, 2022-20 I.R.B. 1062
2022-20, 2022-21 I.R.B. 1095
2022-24, 2022-21 I.R.B. 1097
Proposed Regulations:
REG-118250-20, 2022-07 I.R.B. 753
REG-105954-20, 2022-11 I.R.B. 828
REG-114209-21, 2022-11 I.R.B. 898
REG-114209-21, 2022-11 I.R.B. 898
REG-121508-18, 2022-15 I.R.B. 996
REG-114339-21, 2022-17 I.R.B. 1030
REG-106384-20, 2022-20 I.R.B. 1076
REG-118913-21, 2022-20 I.R.B. 1089
REG-122770-18, 2022-21 I.R.B. 1104
Revenue Procedures:
2022-1, 2022-01 I.R.B. 1
2022-2, 2022-01 I.R.B. 120
Revenue Procedures:—Continued
2022-3, 2022-01 I.R.B. 144
2022-4, 2022-01 I.R.B. 161
2022-5, 2022-01 I.R.B. 256
2022-7, 2022-01 I.R.B. 297
2022-9, 2022-02 I.R.B. 310
2022-11, 2022-03 I.R.B. 449
2022-8, 2022-04 I.R.B. 451
2022-10, 2022-06 I.R.B. 473
2022-13, 2022-06 I.R.B. 477
2022-12, 2022-07 I.R.B. 494
2022-14, 2022-07 I.R.B. 502
2022-15, 2022-13 I.R.B. 908
2022-17, 2022-13 I.R.B. 930
2022-17, 2022-13 I.R.B. 933
2022-20, 2022-14 I.R.B. 945
2022-21, 2022-16 I.R.B. 1015
2022-23, 2022-18 I.R.B. 1052
2022-24, 2022-20 I.R.B. 1075
2022-22, 2022-21 I.R.B. 1098
Revenue Rulings:
2022-1, 2022-02 I.R.B. 301
2022-2, 2022-04 I.R.B. 451
2022-3, 2022-06 I.R.B. 467
2022-4, 2022-10 I.R.B. 790
2022-5, 2022-10 I.R.B. 792
2022-6, 2022-12 I.R.B. 904
2022-7, 2022-14 I.R.B. 935
2022-8, 2022-14 I.R.B. 936
2022-9, 2022-18 I.R.B. 1041
Treasury Decisions:
9959, 2022-03 I.R.B. 328
9961, 2022-03 I.R.B. 430
9960, 2022-07 I.R.B. 481
9962, 2022-11 I.R.B. 823
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2021.

Bulletin No. 2022–21 iii May 23, 2022
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2022–21
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2020–27 through 2020–52 is in Internal Revenue Bulletin
2020–52, dated December 27, 2021.

Internal Revenue Service
Washington, DC 20224
Official Business
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