Tax TreatmentQuestion 308 of 716

An employee receives $200,000 of EMPLOYER-PAID group term life insurance through a non-discriminatory cafeteria plan. Under IRC §79, the income-tax treatment is:

a.The premium attributable to the FIRST $50,000 of group term coverage is excluded from the employee's gross income under IRC §79; the cost of coverage in excess of $50,000 is imputed to the employee using IRS Uniform Premium Table I rates (based on age), and that imputed cost is added to W-2 wages
b.All employer-paid group term life coverage is fully tax-free to the employee regardless of the face amount, because IRC §79 treats the entire employer premium as a nontaxable fringe benefit whenever the coverage is offered through a non-discriminatory cafeteria plan whose premiums the employer deducts
c.The entire $200,000 face amount, rather than the cost of the coverage, is imputed to the employee each year at Uniform Premium Table I rates and reported as W-2 wages, so the employee is taxed annually on the full death benefit while still living and the beneficiary later collects it tax-free
d.The premium attributable to the first $200,000 of coverage is excluded from income under IRC §79, and only the cost of any coverage above $200,000 is imputed using the Uniform Premium Table I age-based rates, so this employee reports no imputed income on the W-2 at all and the employer withholds no FICA

Explanation

Under IRC §79, the cost of EMPLOYER-PROVIDED group term life insurance is excluded from the employee's gross income only up to the FIRST $50,000 of coverage, which is what the response applying the $50,000 exclusion and imputing the excess at Uniform Premium Table I rates describes. For coverage in excess of $50,000, the IRS calculates the cost using Uniform Premium Table I (an age-based monthly rate per $1,000 of excess coverage), reduces it by any after-tax employee contributions, and adds the net amount to the employee's W-2 wages as IMPUTED INCOME (subject to income tax and FICA but generally not federal unemployment tax). For a $200,000 policy, $150,000 of excess coverage generates imputed income each year based on the employee's age. The response imputing the entire $200,000 face amount overstates by taxing the face amount itself rather than the cost of the coverage. The response making all employer-paid group term coverage tax-free regardless of face amount ignores the $50,000 cap. The response excluding the first $200,000 and imputing only coverage above that is reversed. This is one of the most frequently tested taxation rules.

Law Reference: IRC §79 (group term life imputed income / Table I)

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