Plan may use substitute male mortality tables
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This page covers one taxpayer's ruling from 2016, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.
Plain-English summary
A single-employer defined benefit plan asked to use substitute mortality tables for its male population when making computations under section 430. The IRS approved the request for up to ten years beginning with the plan year starting January 1, 2016. The approved rates were based on the plan's mortality experience from 2010 through 2013 and used 2011 as the base year. The approval may end early if the population loses credible mortality experience, controlled-group requirements are not met, the covered population changes significantly, the table stops predicting mortality accurately, or replacement-table guidance applies. The IRS reviewed the development and fit of the mortality rates but did not approve the accuracy of other calculations or submitted material.
Ruling snapshot
- Question: May the plan use substitute mortality tables for its male population under section 430?
- Outcome: Yes, for up to ten years beginning with the 2016 plan year, subject to early-termination rules.
- Key authorities: IRC § 430(h)(3); Treas. Reg. §§ 1.430(h)(3)-1 and 1.430(h)(3)-2
Full text (IRS public release)
Significant Index No. 0430.00-00
DEPARTMENT OF THE TREASURY
INTERNAL REVENUE SERVICE
WASHINGTON, D.C. 20224
NOV 19 2015
Re:
EIN: , Plan No. (the “Plan”)
Dear :
This letter is to inform you that your request to use substitute mortality tables for making
computations under section 430 of the Internal Revenue Code (the “Code”) for the male
subpopulation of the Plan has been granted with respect to the populations specified in
this letter, effective for a period of up to 10 years beginning with the plan year
commencing January 1, 2016. Your request has been granted in accordance with
section 430(h)(3) of the Code and section 303(h)(3) of the Employee Retirement
Income Security Act of 1974 (“ERISA”).
In granting this approval, we have considered only the development of the substitute
mortality rates and whether they sufficiently reflect the mortality experience of the
applicable plan populations. Accordingly, we are not expressing any opinion as to the
accuracy or acceptability of any calculations or other material submitted with your
request.
Permission is hereby granted to use the male substitute mortality rates shown in the
following table:
Age Males Age Males Age Males Age Males
1 0.000510 10 0.000170 19 0.000268 28 0.000372
2 0.000344 11 0.000175 20 0.000279 29 0.000390
3 0.000286 12 0.000183 21 0.000292 30 0.000420
4 0.000223 13 0.000192 22 0.000303 31 0.000472
5 0.000204 14 0.000206 23 0.000316 32 0.000532
6 0.000195 15 0.000218 24 0.000326 33 0.000597
7 0.000187 16 0.000230 25 0.000337 34 0.000664
8 0.000173 17 0.000244 26 0.000354 35 0.000732
9 0.000167 18 0.000256 27 0.000362 36 0.000796
2
Age Males Age Males Age Males Age Males
37 0.000856 58 0.003854 79 0.045520 100 0.343266
38 0.000902 59 0.004278 80 0.051642 101 0.358489
39 0.000945 60 0.004743 81 0.058213 102 0.371800
40 0.000988 61 0.005252 82 0.065129 103 0.382901
41 0.001034 62 0.005804 83 0.071920 104 0.391499
42 0.001089 63 0.006528 84 0.078657 105 0.397297
43 0.001153 64 0.007445 85 0.086043 106 0.400000
44 0.001231 65 0.008528 86 0.094779 107 0.400000
45 0.001321 66 0.009752 87 0.105753 108 0.400000
46 0.001410 67 0.011091 88 0.118952 109 0.400000
47 0.001509 68 0.012489 89 0.134079 110 0.400000
48 0.001619 69 0.013964 90 0.150839 111 0.400000
49 0.001739 70 0.015599 91 0.168938 112 0.400000
50 0.001870 71 0.017476 92 0.188079 113 0.400000
51 0.001983 72 0.019681 93 0.207966 114 0.400000
52 0.002136 73 0.022084 94 0.228305 115 0.400000
53 0.002330 74 0.024631 95 0.248800 116 0.400000
54 0.002559 75 0.027512 96 0.269155 117 0.400000
55 0.002825 76 0.030919 97 0.289075 118 0.400000
56 0.003129 77 0.035043 98 0.308263 119 0.400000
57 0.003471 78 0.039952 99 0.326426 120 1.000000
The above tables will be used for all males in the Plan The above rates were developed
based on an experience study period from January 1, 2010, through December 31,
2013, and were calculated using the Karup-King method. The base year for the
resulting tables is 2011. The Internal Revenue Service has reviewed the substitute
mortality rates and supporting information, and has determined that based on the
information submitted, the rates sufficiently reflect the mortality experience of the
applicable populations within the Plan.
Your attention is called to section 430(h)(3)(C)(ii) of the Code, section 303(h)(3)(C)(ii) of
ERISA, and section 1.430(h)(3)-2(d)(4) of the regulations, which describe the
circumstances in which the use of the substitute mortality table will terminate before the
end of the 10-year period described above. In general, the substitute mortality tables
can no longer be used as of the earliest of:
(1) The plan year in which the plan fails to satisfy the requirements of paragraph
1.430(h)(3)-2(c)(1) of the regulations, requiring that the groups for which
substitute mortality tables is used must have credible mortality experience,
(2) The plan year in which the plan fails to satisfy the requirements of paragraph
1.430(h)(3)-2(d)(1) of the regulations, regarding the requirement that other plans
and populations in the controlled group must use substitute mortality tables
3
unless it can be demonstrated that they do not have credible mortality
experience,
(3) The second plan year following the plan year in which there is a significant
change in individuals covered by the plan as described in paragraph
1.430(h)(3)-2(d)(4)(ii) of the regulations (generally applicable when there is a
change of 20% or more in the number of individuals in the population for which
the substitute mortality table is used),
(4) The plan year following the plan year in which a substitute mortality table used
for a plan population is no longer accurately predictive of future mortality of that
population, as determined by the Commissioner or as certified by the plan’s
actuary to the satisfaction of the Commissioner, and
(5) The date specified in guidance published in the Internal Revenue Bulletin
pursuant to a replacement of mortality tables specified under section
430(h)(3)(A) and 1.430(h)(3)-1, other than annual updates to the static mortality
tables issued pursuant to 1.430(h)(3)-1(a)(3) of the regulations.
This ruling is directed only to the taxpayer that requested it. Section 6110(k)(3) of the
Code provides that it may not be used or cited by others as precedent.
When filing Form 5500 for the plan years for which the substitute mortality tables are
used, please note the information that is required to be attached to Schedule SB
(Actuarial Information) in accordance with the instructions to that form.
We have sent a copy of this letter to your Authorized Representatives pursuant to a
power of attorney on file in this office and to the Manager, EP Classification in
Baltimore, Maryland and to the Manager, EP Compliance Unit in Chicago, Illinois.
If you require further assistance in this matter, please contact
(ID# ) at ( ) - .
Sincerely,
David M. Ziegler, Manager
Employee Plans Actuarial Group 2
cc:
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