### Question
What is the definition of qualified reformation?


### Answer
The definition of **qualified reformation** is as follows in *26 U.S.C. § 2055*:

> a change of a governing instrument by reformation, amendment, construction, or otherwise which changes a reformable interest into a qualified interest but only if—



(i) any difference between—



(I) the actuarial value (determined as of the date of the decedent's death) of the qualified interest, and



(II) the actuarial value (as so determined) of the reformable interest,


  

does not exceed 5 percent of the actuarial value (as so determined) of the reformable interest,



(ii) in the case of—



(I) a charitable remainder interest, the nonremainder interest (before and after the qualified reformation) terminated at the same time, or



(II) any other interest, the reformable interest and the qualified interest are for the same period, and


  


(iii) such change is effective as of the date of the decedent's death

#### Citation:
  - *26 U.S.C. § 2055*
  - Heading: **Subtitle B-Estate and Gift Taxes > CHAPTER 11-ESTATE TAX > Subchapter A-Estates of Citizens or Residents > PART IV-TAXABLE ESTATE**

