Comments Concerning IRS Notice 2001–10
April 2001 III. Standardized SDA Table to Value Economic Benefits - Survivorship Table
We suggest that the IRS publish a table that may be used by taxpayers to report death benefit coverage under a second to die, or so called "survivorship" arrangement. Employers currently report income under survivorship SDAs using U.S. 38 tables. We understand that these tables are based upon the now revoked P.S. 58 rates, thereby creating uncertainty as to what is the appropriate method to report the value of term protection under a survivorship SDA. If a survivorship table cannot be published before year end, additional guidance should be provided before year end regarding whether the U.S. 38 tables may continued to be used, and if not, how term coverage under survivorship SDAs should be reported until the IRS publishes final tables.
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