Schedule SB

[nancy]

Was there any input from the IRS at the ACOPA meeting regarding these questions? Should the carryover balance be subtracted in order to determine the FTAP and AFTAP?

[Guest robertwa]

I think for the FTAP in 14 you always subtract out both the COB and PFB: FTAP = (AVA - COB - PFB)/ not-at-risk FT

For the AFTAP in 15, you also subtract out both the COB and PFB, unless AVA/not-at-risk FT ≥ 92% (92% is the threshold for 2008 - the threshold percentages are 94% for 2009, 96% for 2010 and 100% thereafter, but once you fail the test the threshold is 100% for all years from then on).

In summary: if AVA/not-at-risk FT < threshold percentage, then AFTAP = (AVA - COB - PFB + Annnuity Purchases)/(not-at-risk FT + Annuity purchases)

If AVA/not-at-risk FT ≥ threshold percentage, then AFTAP = (AVA + Annuity Purchases)/(not-at-risk FT + Annuity Purchases)