752.0.10.10.5. The rules to which section 752.0.10.10.4 refers in respect of an individual are as follows:(a) for the purposes of this chapter, except section 752.0.10.10.4, and of sections 985.1 to 985.22, 985.23.1 to 985.23.7, 985.23.9, 985.23.10, 985.24, 985.25 and 999.2, the transfer referred to in section 752.0.10.10.4 is deemed to be a gift made immediately before the individual’s death by the individual to the qualified donee referred to in section 752.0.10.10.4; and
(b) the fair market value of the gift is deemed to be equal to the fair market value, at the time of the individual’s death, of the right to the transfer, determined without reference to any risk of default with regard to the obligations of the issuer of the arrangement described in section 752.0.10.10.4.