Comments Concerning IRS Notice 2001–10
III. Standardized SDA Table to Value Economic Benefits
- Reflecting Actual Mortality Expense to Determine Economic Benefit
Further review may be advisable to determine if Table 2001 rates overstate the value of the employee's economic benefit under Equity SDAs. We understand that Table 2001 is based on group insurance rates, which reflect the additional risk insurers incur by automatically covering every employee. The P.S. 58 rates, while outdated, are based on individual term life insurance underwriting costs.