Actuarial Values, Version 3B: Unitrust Remainder Examples - For One Life, Two Lives, and Terms Certain. For Use in Income, Estate, and Gift Tax Purposes. (Revised May, 2009)

摘要

This publication sets forth examples for using actuarial factors for certain income, gift, and estate tax valuations of future interests. This publication does not contain the tables of actuarial factors used in these examples. The actuarial tables cited in the examples below can be found on the IRS website at the following address: http://www.irs. gov/retirement/article/ 0,,id=206601,00.html. The examplesprovided are for the computation of interests in unitrusts. A unitrust is a trust wherein the trustee is directed to pay annually a fixed percentage of the fair market value of the trust computed each year, either for a life or lives or for a term of years, or for a combination of lives and years. The fixed percentage is called the payout rate. If payments are made other than annually at the beginning of each year, thepayout rate must be adjusted (using Table F) in order to compute the interest involved. Some unitrusts may pay the lesser of a stated payout rate or the net trust income for the year (sometimes referred to as a Net Income Charitable Remainder Unitrust). Example 1 provides the methodof computing the Adjusted Payout Rate given the trusts stated payout rate and the section 7520 interest rate. Example 2 provides the valuation of the remainder interest in a unitrust which continues until the death of a single person. Example 3 shows the method for computing the remainder interest following the death of the last to die of two persons. Example 4 illustrates the computation of the term estate interest in a unitrust which continues for a term certain. Example 5 shows the computation of a remainder interest following the earlier to occur of either the death of a person or the end of a term of years.