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Adoption Of 94GAR Table


Guest merlin
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Guest merlin

We're using the Corbel/Relius volume submitter plans for our GUST restaements.Corbel includes 94GAR adoption language in their EGTRRA amendment. The Corbel RAP expires 4/30/03, but in reading Rev. Rul. 2001-62 it looks like our db plans must adopt 94GAR by 12/31/02. This means that we either have to get our db GUST/EGTRRA amendments done by 12/31/02, or have our db plans adopt the appropriate 2001-62 model amendment by 12/31/02. Am I reading this correctly?

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Merlin, it depends when you are electing to use the 94 GAR Table. If you are electing to use it in 2002, then you need to amend the plan by the last day of the plan year in which you began to use it. If you elect to wait until it is required to be used (after December 31, 2002), you have until the end of that plan year to make the amendment.

So for a calendar year plan where you are waiting until 2003 to use the 94 GAR Table, you have until 12/31/03 to amend your plan.

"What's in the big salad?"

"Big lettuce, big carrots, tomatoes like volleyballs."

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Guest merlin

Thanks,Blinky. But what's troubling me is the effective date ON OR AFTER 12/31/02. I'm reading this to mean that I must use the 94GAR table for pye 12/31/02 and that means I have to amend by 12/31/02. I can use it earlier in 02 if I want,but no later. Am I being too stringent?

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http://www.taxlinks.com/rulings/2001/revrul2001-62.htm

I believe that the table is required for "annuity starting dates on or after 12/31/02". The plan year is not relevant. It can be adopted with an earlier effective date.

The adoption date is no later than the last day of the plan year which contains the effective date.

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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  • 4 weeks later...
Guest lisbetf

What if your current document doesn't specify the table name, but instead says "the applicable mortality table as prescribed by/..."? Can't you wait until your GUST remedial amendment period is up to amend for this?

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Does anyone agree with me that Rev. Proc. 2002-73 DOES NOT extend the amendment date under 2001-62 for calendar year plans that are individual plans? Under Rev. Proc. 2002-73, the "later of" date is now tagged to the 2001-62 date and the GUST remedial amendment period. See section 4.01. Since the GUST remedial amendment period is long gone for calendar year individual plans, I see no helpful extension.

:mad:

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