Treasury Regulations · 26 CFR
§ 25.2512-5A. Valuation of annuities, interests for life or a term of years, and remainder or reversionary interests transferred before June 1, 2023.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 2512
Cite as 26 CFR § 25.2512-5A
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- June 10, 1994 by T.D. 8540
- Last amended
- June 7, 2023 by T.D. 9974
- Issued under
- 26 U.S.C. § 2512
- Length
- 5,459 words · about 24 min to read
- Cross-references
- cites 2 Code sections and 10 regulations; cited by 7
the donor shall make an election. The donor may elect to value both interests transferred in 1983 under § 25.2512-5A(c) as if such section applied to all transfers made before January 1, 1984, or the donor may elect to have both interests transferred valued under this section. The donor shall indicate the election being made in a statement attached to the donor's gift tax return for 1983.
the donor shall make an election. The donor may elect to value the interest transferred in 1984 under § 25.2512-5A(c) as if such section applied to all transfers made before January 1, 1985, or the donor may elect to have the transfer valued under this section. If the donor elects to value the interest transferred in 1984 under § 25.2512-5A(c), the donor shall indicate that the election is being made by attaching a statement to the donor's gift tax return for 1984. If the donor elects to value the interest transferred in 1984 under this section the election shall not be effective unless the donor declares, in a statement attached to the donor's gift tax return for 1984, that the donor has filed an amended gift tax return for 1983, in which the donor has revalued the transfers made in the first eleven months of 1983 under this section as if this section applied to transfers made after December 31, 1982.
The donor assigns an annuity of $10,000 a year payable annually during the donor's life immediately after an annual payment has been made. The age of the donor on the date of assignment is 40 years and eight months. By reference to Table A, it is found that the figure in column 2 opposite 41 years is 9.1030. The value of the gift is, therefore, $91,030 ($10,000 multiplied by 9.1030).
The donor was entitled to receive an annuity of $10,000 a year payable annually at the end of annual periods throughout a term of 20 years. The donor, when 15 years have elapsed, makes a gift thereof to the donor's son. By reference to Table B, it is found that the figure in column 2 opposite five years, the unexpired portion of the 20-year period, is 3.7908. The present value of the annuity is, therefore, $37,908 (10,000 multiplied by 3.7908).
1.0244 for semiannual payments,
1.0368 for quarterly payments,
1.0450 for monthly payments,
1.0482 for weekly payments.
If the annuity is payable at the end of semiannual, quarterly, monthly, or weekly periods for a definite number of years the aggregate amount to be paid within a year is first multiplied by the figure in column 2 of Table B opposite the number of years in column 1 representing the duration of the annuity. The product so obtained is then multiplied by whichever of the above factors is appropriate. The application of this paragraph (d)(2)(ii) may be illustrated by the following example:
The facts are the same as those contained in example (1) set forth in paragraph (d)(2)(i) above, except that the annuity is payable semiannually. The aggregate annual amount, $10,000 is multiplied by the factor 9.1030, and the product multiplied by 1.0244. The value of the gift is, therefore, $93,251.13 ($10,000 × 9.1030 × 1.0244).
The donee is made the beneficiary for life of an annuity of $50 a month from the income of a trust, subject to the right reserved by the donor to cause the annuity to be paid for the donor's own benefit or for the benefit of another. On the day a payment is due, the donor relinquishes the reserved power. The donee is then 50 years of age. The value of the gift is $50 plus the product of $50 × 12 × 8.4743 (see Table A) × 1.0450. That is, $50 plus $5,313.39, or $5,363.39.
1.1000 for annual payments,
1.0744 for semiannual payments,
1.0618 for quarterly payments,
1.0534 for monthly payments, or
1.0502 for weekly payments.
The application of this paragraph (d)(2)(iii)(B) may be illustrated by the following example:
The donee is the beneficiary of an annuity of $50 a month, subject to a reserved right in the donor to cause the annuity or the cash value thereof to be paid for the donor's own benefit or the benefit of another. On the day a payment is due, the donor relinquishes the power. There are 300 payments to be made covering a period of 25 years, including the payment due. The value of the gift is the product of $50 × 12 × 9.0770 (factor for 25 years Table B) × 1.0534, or $5,737.03.
The donor who during the donor's life is entitled to receive the income from property worth $50,000, makes a gift of such interest. The donor is 31 years old on the date of the gift. The value of the gift is $47,627 ($50,000 × .95254).
The donor transfers by gift a remainder interest in property worth $50,000, subject to the donor's sister's right to receive the income therefrom for her life. The sister at the date of the gift is 31 years of age. By reference to Table A it is found that the figure in column 4 opposite age 31 is .04746. The value of the gift is, therefore, $2,373 ($50,000 × .04746).
[T.D. 8540, 59 FR 30173, June 10, 1994, as amended at 59 FR 30173, 30174, June 10, 1994; T.D. 8819, 64 FR 23226, Apr. 30, 1999; T.D. 8886, 65 FR 36943, June 12, 2000; T.D. 9448, 74 FR 21515, May 7, 2009; T.D. 9540, 76 FR 49641, Aug. 10, 2011; T.D. 9974, 88 FR 37459, June 7, 2023]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 25.2512-5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.
- § 25.2512-6 Valuation of certain life insurance and annuity contracts; valuation of shares in an open-end investment company.
- § 1.664-3 Charitable remainder unitrust.
- § 1.664-4 Calculation of the fair market value of the remainder interest in a charitable remainder unitrust.
- § 1.642(c)-5 Definition of pooled income fund.
- § 1.642(c)-6 Valuation of a remainder interest in property transferred to a pooled income fund.
- § 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 June 1, 2023.
- § 20.2031-7 Valuation of annuities, interests for life or term of years, and remainder or reversionary interests.
- § 601.201 Rulings and determinations letters.
- § 25.7520-1 Valuation of annuities, unitrust interests, interests for life or terms of years, and remainder or reversionary interests.
Cited by 7 other regulations
- § 1.170A-12 Valuation of a remainder interest in real property for contributions made after July 31, 1969.
- § 1.170A-14 Qualified conservation contributions.
- § 25.2512-5 Valuation of annuities, unitrust interests, interests for life or term of years, and remainder or reversionary interests.
- § 25.2522(c)-3 Transfers not exclusively for charitable, etc., purposes in the case of gifts made after July 31, 1969.
- § 25.2523(a)-1 Gift to spouse; in general.
- § 25.2523(c)-1 Interest in unidentified assets.
- § 25.7520-4 Transitional rules.
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Amended by T.D. 9974 (88 FR 37459)
- Amended by T.D. 9540 (76 FR 49641)
- Amended by T.D. 9448 (74 FR 21515)
- Amended by T.D. 8886 (65 FR 36943)
- Amended by T.D. 8819 (64 FR 23226)
- Date not givenAmended (59 FR 30173)
- Issued by T.D. 8540 (59 FR 30173)
Where it sits in 26 CFR
- Subchapter B Estate and gift taxes
- Part 25 Gift tax; gifts made after december 31, 1954
- Actuarial Tables Applicable Before June 1, 2023