Which mortality table to use?

[FAPInJax]

The IRS has blessed the mortality tables contained in IRC 404 regulations under Standard mortality tables. I seem to remember seeing something that also permitted the use of GATT and GAR. Am I mistaken and if not would someone please provide a cite.

Thanks in advance.

[Tom Poje]

last sentence of 1.401(a)(12) definitions of Standard Mortality Table

[FAPInJax]

The last sentence allows the commissioner may change the definition of the mortality tables.

The question is has he?? (Specifically with permitting the use of GATT and/or GAR)

[FAPInJax]

Eureka! I found it where the commissioner stated that the mortality table which is used for minimum lump sums can be used for nondiscrimination testing. Therefore, GAR is currently an option for current plan years and GATT (no longer OK but was OK for earlier years).

An interesting note is that PPA requires the use of a mortality table that 'improves' each year. I can't wait for the nondiscrimination issues to crop up when plans do not pass simply because the mortality changed <GG>.

Thanks for your response.

[Tom Poje]

I'd recomend getting a new book!

1.401(a)(4)-12 was amended way way back (TD 6/29/2001)

the last sentence now reads

The applicable mortality table under section 417(e)(3)(A)(ii)(I) is also a standard mortality table.

[AndyH]

Which book?

[Tom Poje]

well, I am looking at a copy of the Thompson/RIA book (which is simply a reprint of the Code and the Regulations. - no commentary, nothing extra)

or you could use CCH, which is the same the same thing.

I imagine there are others. I was not referring to any of the Pension Answer Books or the ERISA Outline Book.

sorry about that - I certainly didn't mean to be confusing

[AndyH]

No, you missed my slant.

I thought this would be a topic for something authoritative such as the NonDiscrimination Answer Book.