Dependent Group-Term Life Insurance

[Guest Jack]

I am trying to understand IRS Notice 89-110, which states that for plan years ending on or before December 31, 1991, dependent group-term life insurance cannot be included in a cafeteria plan without violating 1.125-2 Q&A-4(d)if such benefit would also be eligible for exclusion under Section 132 if offered outside a cafeteria plan. Does this mean you may never include dependent life insurance coverage in a cafeteria plan? Or, does it mean that you can include dependent coverage if it does not qualify as a de minimis fringe benefit under 132(e)? All opinions are greatly appreciated.

[SLuskin]

I don't think you can ever offer dependent life insurance in a Cafeteria Plan.