"To realize these tax benefits, a disability insurance contract must satisfy all of the following requirements: [1] The insurance contract must provide for payments to the plan if the participant cannot work due to disability. [2] The amount of disability payments may not exceed the reasonably expected amount of annual contributions that would have been made to the plan during the period of disability, reduced by any other contributions credited to the participant's account during such period.... [3] The insurance coverage is not self-insured by the employer, but instead is purchased from a third party insurer."

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