ETL

I appreciate the response. I believe 417(e)-1(d)(6) applies to the explicit, present value, bifurcation approach and 417(e)-1(d)(7), which defines the implicit, annuity value, bifurcation approach is an alternative to the explicit bifurcation.

I'm wondering any one has any insight into calculating the implicit bifurcation (annuity payment bifurcation) for SSLIOs when valued for a joint life such as a 50% J&S SSLIO. Particularly, my team is debating whether or not it is appropriate to use the plan basis for the J&S conversion or the 417(e) basis. When leveling both the participant and beneficiary benefit I can see a defense for either. I can't seem to find any guidance on this so any input would be appreciated. As a corollary, what are your thoughts when leveling just the participant benefit for something like a 50% J&S SSLIO? We're thinking it makes the most sense to use the plan basis for such a case. Thanks for the help!