ETL Posted Wednesday at 09:35 PM Posted Wednesday at 09:35 PM 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!
Effen Posted Wednesday at 10:16 PM Posted Wednesday at 10:16 PM Make sure you carefully review 1.417(e)-1(d)(6)(ii). There is a present value comparison/test is required under 417(e). The material provided and the opinions expressed in this post are for general informational purposes only and should not be used or relied upon as the basis for any action or inaction. You should obtain appropriate tax, legal, or other professional advice.
ETL Posted 10 hours ago Author Posted 10 hours ago 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.
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