Internal Revenue Bulletin 2023-46 (PDF rendition): IRS Announcements

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Bulletin No. 2023–46
November 13, 2023
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
EMPLOYEE PLANS
REG-103525-23, page 1252.
These proposed regulations would update the require-
ments that a plan sponsor of a single-employer defined
benefit plan must meet to obtain IRS approval to use
mortality tables specific to the plan in calculating present
value for minimum funding purposes (as a substitute for
the generally applicable mortality tables).
T.D. 9983, page 1237.
These regulations prescribe mortality tables to be used for
most defined benefit pension plans. The tables specify the
probability of survival year-by-year for an individual based
on age, gender, and other factors. The tables are used
(together with other actuarial assumptions) to calculate the
present value of a stream of expected future benefit pay-
ments for purposes of determining the minimum funding
requirements for the plan. These mortality tables are also
relevant for determining the minimum required amount of a
lump-sum distribution from such a plan.
EXEMPT ORGANIZATIONS
Announcement 2023-31, page 1251.
Revocation of IRC 501(c)(3) Organizations for failure to meet
the code section requirements. Contributions made to the
organizations by individual donors are no longer deductible
under IRC 170(b)(1)(A).
Finding Lists begin on page ii.

The IRS Mission
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them understand and meet their tax responsibilities and
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Introduction
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The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
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November 13, 2023 Bulletin No. 2023–46

Part I
26 CFR 1.430(h)(3)-1; 26 CFR 1.431(c)(6)-1; 26
CFR 1.433(h)(3)-1
T.D. 9983
DEPARTMENT OF THE
TREASURY
Internal Revenue Service
26 CFR Part 1
Mortality Tables for
Determining Present Value
under Defined Benefit
Pension Plans
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document sets forth
final regulations prescribing mortality
tables to be used for most defined bene-
fit pension plans. The tables specify the
probability of survival year-by-year for an
individual based on age, gender, and other
factors. The tables are used (together with
other actuarial assumptions) to calculate
the present value of a stream of expected
future benefit payments for purposes of
determining the minimum funding require-
ments for the plan. These mortality tables
are also relevant for determining the min-
imum required amount of a lump-sum
distribution from such a plan. These regula-
tions affect participants in, beneficiaries of,
employers maintaining, and administrators
of certain defined benefit pension plans.
DATES: Effective date: These regulations
are effective October 20, 2023.
Applicability date: These regulations
apply to valuation dates occurring on or
after January 1, 2024.
Incorporation by reference: The incor-
poration by reference of certain publi-
cations listed in the rule is approved by
the Director of the Federal Register as of
October 20, 2023.
FOR FURTHER INFORMATION
CONTACT: Concerning the regulations,
Arslan Malik or Linda Marshall at (202)
317-6700; concerning the construction
of the base mortality tables and the static
mortality tables for 2024, Christopher
Denning at (202) 317-5755 (not toll free).
SUPPLEMENTARY INFORMATION:
Background
Section 412 of the Internal Revenue
Code (Code) prescribes minimum fund-
ing requirements for defined benefit pen-
sion plans, and section 430 specifies the
minimum funding requirements that apply
generally to defined benefit plans that are
not multiemployer plans.
1
Section 430(a)
defines the minimum required contribu-
tion for a plan by reference to the plan’s
funding target for the plan year. Under
section 430(d)(1), a plan’s funding target
for a plan year generally is the present
value of all benefits accrued or earned
under the plan as of the first day of that
plan year.
Section 430(h)(3) provides rules
regarding the mortality tables to be used
under section 430. Under section 430(h)
(3)(A), except as provided in section
430(h)(3)(C) or (D), the Secretary is to
prescribe by regulation mortality tables to
be used in determining any present value
or making any computation under sec-
tion 430. Those mortality tables are to be
based on the actual mortality experience
of pension plan participants and projected
trends in that experience. In prescribing
those mortality tables, the Secretary is
required to take into account results of
available independent studies of mortality
of individuals covered by pension plans.
Under section 430(h)(3)(B), the Secretary
is required to revise any mortality table in
effect under section 430(h)(3)(A) at least
every 10 years to reflect actual mortality
experience of pension plan participants
and projected trends in that experience.
Under section 430(h)(3)(C), a plan spon-
sor may request the Secretary’s approval
to use plan-specific substitute mortality
tables that meet requirements specified
in the statute rather than the generally
applicable mortality tables. If approved,
the substitute mortality tables are used to
determine present values and make com-
putations under section 430 during the
period of consecutive plan years (not to
exceed 10) specified in the request.
Section 430(h)(3)(D) provides for
the use of separate mortality tables with
respect to certain individuals who are enti-
tled to benefits on account of disability.
These separate mortality tables are per-
mitted to be used with respect to disabled
individuals in lieu of the generally appli-
cable mortality tables provided pursuant
to section 430(h)(3)(A). The Secretary is
to establish separate tables for individuals
with disabilities occurring in plan years
beginning before January 1, 1995, and for
individuals with disabilities occurring in
later plan years, with the mortality tables
for individuals with disabilities occurring
in those later plan years applying only to
individuals who are disabled within the
meaning of Title II of the Social Security
Act.
2
Section 417(e)(3) generally provides
that the present value of certain benefits
under a qualified pension plan (includ-
ing single-sum distributions) must not be
less than the present value of the accrued
benefit using applicable interest rates and
the applicable mortality table. Section
417(e)(3)(B) defines the term “applica-
ble mortality table” as the mortality table
specified for the plan year for minimum
funding purposes under section 430(h)(3)
1
Section 302 of the Employee Retirement Income Security Act of 1974, Pub. L. No. 93-406, 88 Stat. 829 (1974), as amended (ERISA), sets forth funding rules that are parallel to those in
section 412 of the Code, and section 303 of ERISA sets forth additional funding rules for defined benefit plans (other than multiemployer plans) that are parallel to those in section 430 of the
Code. Pursuant to section 101 of Reorganization Plan No. 4 of 1978, 5 U.S.C. App., as amended, the Secretary of the Treasury has interpretive jurisdiction over the subject matter addressed
in these regulations for purposes of ERISA, as well as the Code. Thus, these Treasury regulations issued under section 430 of the Code also apply for purposes of section 303 of ERISA.
Similarly, Treasury regulations under sections 431 and 433 apply for purposes of sections 304 and 306 of ERISA.
2
Mortality tables that were permitted to be used for disabled participants under section 412(l)(7)(C)(iii)(I) as in effect before 2008 were provided in Rev. Rul. 96-7, 96-3 IRB 12. Notice
2008-29, 2008-1 CB 637, adopted those tables for use under section 430(h)(3)(D).
Bulletin No. 2023–46 1237 November 13, 2023

(A) (without regard to the rules for substi-
tute mortality tables under section 430(h)
(3)(C) or mortality tables for disabled indi-
viduals under section 430(h)(3)(D)), mod-
ified as appropriate by the Secretary. The
modifications made by the Secretary to
the section 430(h)(3)(A) mortality table to
determine the section 417(e)(3)(B) appli-
cable mortality table are not addressed in
these regulations. Revenue Ruling 2007-
67, 2007-2 CB 1047, describes the mod-
ifications that are currently applied to
determine the section 417(e)(3)(B) appli-
cable mortality table.
Final regulations under section 430(h)
(3) were published in the Federal Register
on October 5, 2017, in TD 9826, 82 FR
46388 (the 2017 regulations). Section
1.430(h)(3)-1 prescribes base mortality
tables and a set of mortality improvement
rates, which may be reflected through the
use of either generational mortality tables
or static mortality tables. The generational
mortality tables are a series of mortality
tables, one for each year of birth, each of
which fully reflects projected trends in
mortality rates. The static mortality tables
(which are updated annually
3
) use a sin-
gle mortality table for all years of birth to
approximate the present value that would
be determined using the generational mor-
tality tables.
The mortality tables included in the
2017 regulations are based on the mor-
tality tables included in the RP-2014
Mortality Tables Report
4
(referred to in
this preamble as the RP-2014 mortal-
ity tables), which was released by the
Retirement Plan Experience Committee
(RPEC) of the Society of Actuaries (SOA)
in October 2014 (as revised in November
2014), and a set of mortality improvement
rates as released by RPEC in the Mortality
Improvement Scale MP-2016 Report.
5

In 2016, RPEC initiated a study of pri-
vate-sector retirement plans in the U.S. in
order to provide an update to the RP-2014
mortality tables, and in 2019, RPEC
issued the Pri-2012 Private Retirement
Plans Mortality Tables Report (Pri-2012
Report).
6
In October 2021, RPEC pub-
lished the Mortality Improvement Scale
MP-2021 Report (MP-2021 Report),
which includes the latest mortality
improvement scale issued by RPEC.
7
The standards prescribed for devel-
oping the mortality tables under section
430(h)(3)(A) are the same as the stan-
dards that are prescribed for developing
mortality tables for multiemployer plans
under section 431(c)(6)(D)(iv)(II) (which
are used to determine current liability
in order to determine the minimum full
funding limitation under section 431(c)(6)
(B)). These standards also apply for CSEC
plans described in section 414(y) for pur-
poses of developing mortality tables that
are used for purposes of section 433(h)
(3)(B)(i) (to determine current liability in
order to determine the minimum full fund-
ing limitation under section 433(c)(2)(C)
and the funded current liability percentage
under section 433(i)).
Proposed regulations to update the mor-
tality tables issued under section 430(h)
(3) and make certain other changes
regarding those tables were published in
the Federal Register on April 28, 2022
(87 FR 25161) (the proposed regulations).
Five comments on the proposed regu-
lations were received. No commenters
requested to speak at the scheduled public
hearing; accordingly, the public hearing
was canceled.
On October 27, 2022, RPEC released
a report titled the “RPEC 2022 Mortality
Improvement Update.”
8
Unlike RPEC’s
previously issued reports regarding mor-
tality improvement, this report does not
include a new mortality improvement
scale. RPEC noted that, as of the date of
that report, the most recent year for which
full-year mortality data was available was
2020, which was severely affected by the
COVID-19 pandemic. RPEC concluded
that it would not be appropriate to incor-
porate, without adjustment, the substan-
tially higher rates of mortality experience
from 2020 into the models RPEC had pre-
viously used to project future mortality.
9

Therefore, RPEC chose not to release a
new mortality improvement scale in 2022.
Instead, RPEC recommended the use of
an assumed increase in mortality rates to
reflect the impact of the COVID-19 pan-
demic, which would be phased out after
an appropriate period. RPEC did not rec-
ommend a specific level for this assumed
increase but provided data about mortal-
ity rates for 2020 through the first half of
2022 and provided examples of assumed
increases that could be used (including the
assumed increase used in the 2022 Annual
Report of the Board of Trustees of the
Federal Old-Age and Survivors Insurance
and Federal Disability Insurance Trust
Funds).
Section 335 of the SECURE 2.0 Act
of 2022 (SECURE 2.0 Act), which was
enacted on December 29, 2022 as Division
T of the Consolidated Appropriations Act,
2023, Pub. L. 117-328 (136 Stat. 4459),
instructs the Secretary or the Secretary’s
delegate to amend the regulations under
section 430(h)(3)(A) no later than June
30, 2024. Under this provision, for val-
uation dates occurring during or after
2024, the mortality improvement rates
specified in those regulations must not
assume for years beyond the valuation
date mortality improvements at any age
that are greater than 0.78 percent. Section
335 of the SECURE 2.0 Act also instructs
the Secretary (or delegate) to modify the
0.78 percent limitation to reflect material
changes in the overall rate of improve-
ment projected by the Social Security
Administration.
After consideration of public com-
ments received on the proposed regula-
tions (and taking into account section 335
of the SECURE 2.0 Act), the proposed
regulations are adopted by this Treasury
decision, with certain changes. These
changes include: (1) a delay in the appli-
cability date; (2) modifications in the
mortality improvement rates to reflect the
3
Static mortality tables were published in Notice 2017-60, 2017-43 IRB 365, Notice 2018-02, 2018-2 IRB 281, Notice 2019-26, 2019-15 IRB 943, Notice 2019-67, 2019-52 IRB 1510, Notice
2020-85, 2020-51 IRB 1645, and Notice 2022-22, 2022-20 IRB 1057.
4
This report is available at https://www.soa.org/globalassets/assets/files/research/exp-study/research-2014-rp-report.pdf.
5
This report is available at https://www.soa.org/globalassets/assets/Files/Research/Exp-Study/mortality-improvement-scale-mp-2016.pdf.
6
This report is available at https://www.soa.org/globalassets/assets/files/resources/experience-studies/2019/pri-2012-mortality-tables-report.pdf.
7
This report is available at https://www.soa.org/globalassets/assets/files/resources/experience-studies/2021/2021-mp-scale-report.pdf.
8
This report is available at https://www.soa.org/resources/research-reports/2022/rpec-mortality-improvement/.
9
RPEC noted that, if it had used its standard graduation model and had included 2020 data in accordance with its usual practice, this would have had the effect of elevating mortality improve-
ment rates for periods prior to the pandemic.
November 13, 2023 1238 Bulletin No. 2023–46

Bulletin No. 2023–46 1239 November 13, 2023
expected ongoing impact of COVID-19
on mortality rates and to reflect the 0.78
percent annual cap on mortality improve-
ment rates as required by section 335 of
the SECURE 2.0 Act; and (3) a minor
change related to the treatment of indi-
viduals who are not identified as male or
female.
Summary of Comments and
Explanation of Revisions
These regulations set forth the updated
methodology for determining the gener-
ally applicable mortality tables that are
used to calculate present value under sec-
tion 430 of the Code. Pursuant to section
417(e)(3)(B), a modified version of these
tables is used for purposes of determining
the amount of a single-sum distribution
(or another accelerated form of distribu-
tion). In addition, these tables are used to
determine current liability for multiem-
ployer plans under section 431(c)(6) and
CSEC plans under section 433(h).
The updated methodology for deter-
mining the generally applicable mortal-
ity tables under section 430(h)(3)(A) is
issued pursuant to the requirement under
section 430(h)(3)(B) to revise the mortal-
ity tables used under section 430 to reflect
the actual mortality experience of pension
plan participants and projected trends in
that experience as well as the requirement
under section 335 of the SECURE 2.0
Act that mortality improvement rates pro-
vided under the regulations for years after
the year that includes the applicable val-
uation date may not exceed 0.78 percent
per year. As under the 2017 regulations
and the proposed regulations, the method-
ology for determining generally applica-
ble mortality tables involves the separate
determination of base mortality tables and
the projection of mortality improvement.
A. Base Mortality Tables
These regulations adopt the base mor-
tality tables set forth in the proposed
regulations for use under section 430(h)(3)
(A) of the Code, which are derived from
the tables set forth in the Pri-2012 Report.
No commenter suggested any alternative
source for base mortality tables.
Like the base mortality tables provided
in the 2017 regulations, the base mortality
tables set forth in these regulations are gen-
der-distinct and provide separate non-an-
nuitant and annuitant mortality rates. The
base mortality tables have a base year of
2012 (the central year of the experience
study used to develop the mortality tables
in the Pri-2012 Report). These base tables
generally have the same mortality rates
as the employee and non-disabled annu-
itant mortality rates (amounts weighted)
that were released by RPEC in connec-
tion with the Pri-2012 Report. However,
these base tables also include non-annui-
tant mortality rates for ages below 18 and
above 80 and annuitant mortality rates for
ages below age 50. This generally is the
same approach that was used to develop
the base mortality tables in the 2017 reg-
ulations. The preamble to the proposed
regulations describes the methodology
that was used to develop non-annuitant
mortality rates for ages below age 18 and
above age 80 and annuitant mortality rates
for ages below age 50. See 87 FR 25161,
25163.
B. Mortality Improvement
These regulations adopt the method-
ology set forth in the proposed regula-
tions regarding the adjustment of the base
mortality tables to reflect expected trends
in mortality improvement but use dif-
ferent mortality improvement rates. The
proposed regulations applied the Scale
MP-2021 Rates (the mortality improve-
ment scale in the MP-2021 Report) for
valuation dates in the 2023 calendar
year. This mortality improvement scale
was developed using the same underly-
ing methodology used to develop earlier
mortality improvement scales but reflects
historical population data through 2019
and the change to the RPEC-selected
assumptions for the long-term rate of mor-
tality improvement that was first incorpo-
rated in the Mortality Improvement Scale
MP-2020 Report.
10

One commenter expressed concern that
the expected long-term improvements in
longevity reflected in the MP-2021 Report
may be overly optimistic and suggested
that regulations apply a cap on the long-
term mortality improvement rates used.
Another commenter recommended that
future mortality rates be increased to
reflect the long-term impact of COVID-19.
After considering all the comments and
the RPEC 2022 Mortality Improvement
Update, the Department of the Treasury
(Treasury Department) and the IRS have
decided to adopt a modified version of the
MP-2021 Mortality Improvement Scale
for valuation dates occurring on or after
January 1, 2024. The mortality improve-
ment scale applicable for valuation dates
occurring on or after January 1, 2024,
which is referred to as the 2024 Adjusted
Scale MP-2021 Rates, is based on the
Scale MP-2021 Rates. However, the 2024
Adjusted Scale MP-2021 Rates reflect a
modification to the Scale MP-2021 Rates
that eliminates any mortality improvement
during 2020, 2021, 2022, and 2023 (while
retaining any projected mortality deterio-
ration for those years under the MP-2021
Mortality Improvement Scale).
11
In addi-
tion, in response to the statutory instruc-
tion in section 335 of the SECURE 2.0
Act, the 2024 Adjusted Scale MP-2021
incorporates a cap on mortality improve-
ment rates of 0.78 percent per year for
years after 2024.
12
This cap on mortality
improvement rates is statutorily required
by a clear statutory instruction, and public
comment on the cap rate is unnecessary.
The Treasury Department and the IRS
intend to consider new data regarding
mortality trends of the general popula-
tion as it becomes available (including
future reports and mortality improvement
scales issued by RPEC, as well as projec-
tions of mortality improvement issued
10
This report is available at https://www.soa.org/globalassets/assets/files/resources/experience-studies/2020/mortality-improvement-scale-mp-2020.pdf.
11
Because the mortality rates provided in these regulations apply beginning in 2024 (that is, after the height of the COVID-19 pandemic), the significantly higher rates of mortality experi-
ence during 2020 through 2023 are not determinative of mortality rates for later years. However, the Treasury Department and the IRS expect that mortality in the future will be marginally
higher than what was projected based on mortality experience prior to the COVID-19 pandemic. This expectation has been reflected through the elimination of any mortality improvement
assumption for the years 2020 through 2023.
12
Because the 0.78 percent cap applies to rates for years after the year that includes the applicable valuation date, the first impact of that cap will be on the mortality rates that are projected
to apply in 2025.

November 13, 2023 1240 Bulletin No. 2023–46
by the Social Security Administration)
and to specify new mortality improve-
ment rates that reflect updated data when
future modifications become appro-
priate. Those new mortality improve-
ment rates will incorporate the cap on
mortality improvement rates described
in section 335 of the SECURE 2.0 Act
(including a change to the level of the
0.78 percent cap on annual mortality
improvement rates as a result of any
material changes in the overall rate of
improvement projected by the Social
Security Administration).
C. Use of Static Tables for Small Plans
The 2017 regulations provide for the
use of separate generational non-annuitant
and annuitant mortality tables and sep-
arate static non-annuitant and annuitant
mortality tables. However, the proposed
regulations provided for the elimination
of the use of static mortality tables other
than for small plans. This change was pro-
posed because the Treasury Department
and the IRS believe that there was no
longer a need to allow the use of static
mortality tables for larger plans (as most
actuarial firms have the capability to use
generational mortality tables) and to min-
imize anti-selection by plan sponsors who
determine that the use of static mortality
tables results in lower minimum funding
requirements. No commenters objected to
this change, and these regulations adopt
that change.
D. Individuals not identified as male or
female
One commenter requested that final
regulations clarify how the mortality
tables under section 430(h)(3)(A) are
applied in the case of a participant or ben-
eficiary who identifies as nonbinary. To
address this issue, and to clarify how these
tables should be applied for the portion of
a plan’s population for whom gender data
is not available, the regulations provide
that the plan’s actuary must use a rea-
sonable approach in applying the section
430(h)(3)(A) mortality tables with respect
to the portion of a plan’s population whose
gender is not identified as male or female
(for example, a plan participant who iden-
tifies as nonbinary or for whom gender
is not known). The regulations include
two examples of reasonable approaches
that may be used for this purpose. These
two approaches are merely two reason-
able methods for determining liabilities
with respect to individuals for whom
male or female gender is not identified,
and other reasonable approaches may be
appropriate.
13

Under the first approach, the liabil-
ity for an individual is determined as the
weighted average of the liability calcu-
lated as if the individual were male and
the liability calculated as if the individual
were female, using an appropriate weight-
ing that takes into account the distribu-
tion of gender in the plan’s population for
individuals for whom gender is identified.
For example, if the gender distribution in
a plan’s population for whom the gender
is identified is 2/3 male and 1/3 female,
the liability calculated for the individual
would be equal to 2/3 of the liability cal-
culated as if the individual were male and
1/3 of the liability calculated as if the indi-
vidual were female.
The second approach might be used in
connection with actuarial software that
is not able to apply a weight to individu-
als in the plan census. Under the second
approach, either male or female status
is assigned randomly to an individual
for whom male or female gender is not
identified in a manner that is expected
to result in an appropriate proportion of
males and females for the plan population
that takes into account the distribution of
gender for individuals in the plan’s popu-
lation for whom gender is identified. For
example, if the gender distribution in a
plan population for whom the gender is
identified is 2/3 male and 1/3 female, a
gender may be assigned to an individual
for whom gender is not identified based
on the individual’s birthdate, with some-
one born in the first 8 months of the year
assigned male gender and someone born
in the last 4 months of the year assigned
female gender.
Applicability Date
These regulations apply for valuation
dates occurring on or after January 1,
2024.
Effect of Regulations on Previously
Approved Substitute Mortality Tables
The 2017 regulations also included
rules regarding the use of plan-specific
substitute mortality tables under sec-
tion 430(h)(3)(C), which are set forth in
§ 1.430(h)(3)-2. Section 1.430(h)(3)-2(c)
(6)(ii) provides for the early termination
of the use of substitute mortality tables in
certain circumstances, including in con-
junction with a replacement of the mor-
tality tables specified in § 1.430(h)(3)-1.
Under § 1.430(h)(3)-2(c)(6)(ii)(E), the
early termination in conjunction with a
replacement of the generally applicable
mortality tables will apply as of a date
specified in guidance published in the
Internal Revenue Bulletin. As stated in the
preamble to the proposed regulations, the
Treasury Department and the IRS gener-
ally will not require that the use of previ-
ously approved substitute mortality tables
be terminated solely as a result of replace-
ment of the generally applicable mortality
tables.
Proposed regulations modifying the
rules for approving plan-specific substi-
tute mortality tables are being published in
the proposed rules section of this issue of
the Federal Register. Those regulations
are proposed to apply to plan years begin-
ning on or after January 1, 2025. Until
amendments to the plan-specific substi-
tute mortality regulations are finalized—
and an updated revenue procedure that
reflects the final regulations is issued—the
Treasury Department and the IRS will
not require that any previously approved
plan-specific substitute mortality tables be
terminated pursuant to § 1.430(h)(3)-2(c)
(6)(ii)(E).
Incorporation by Reference
Section 1.430(h)(3)-1(b)(1)(iii) of these
regulations provides that the mortality
13
For example, it might be reasonable to apply an approach based on an equal weighting of male mortality rates and female mortality rates if the gender ratio of the portion of the plan popu-
lation for whom male or female gender is identified is sufficiently close to 50 percent male and 50 percent female.

Bulletin No. 2023–46 1241 November 13, 2023
improvement rates used to construct gen-
erational tables to be used for valuation
dates occurring on or after January 1,
2024, are the 2024 Adjusted Scale
MP-2021 Rates as described in the third
paragraph of section B of the Summary of
Comments and Explanation of Revisions
in this preamble. The Office of the Federal
Register (OFR) has regulations concern-
ing incorporation by reference. 1 CFR part
51. These regulations require that agen-
cies must discuss in the preamble to a rule
or proposed rule the way in which materi-
als that the agency incorporates by refer-
ence are reasonably available to interested
persons, and how interested parties can
obtain the materials. 1 CFR 51.5(b). The
2024 Adjusted Scale MP-2021 Rates may
be found at www.irs.gov/retirement-plans/
pension-plan-mortality-tables.
Statement of Availability of IRS
Documents
IRS Revenue Rulings, Revenue
Procedures, and Notices cited in this
document are published in the Internal
Revenue Bulletin (or Cumulative Bulletin)
and are available from the Superintendent
of Documents, U.S. Government Printing
Office, Washington, DC 20402, or by vis-
iting the IRS website at www.irs.gov.
Special Analyses
Pursuant to the Memorandum
of Agreement, Review of Treasury
Regulations under Executive Order 12866
(June 9, 2023), tax regulatory actions issued
by the IRS are not subject to the require-
ments of section 6 of Executive Order
12866, as amended. Therefore, a regulatory
impact assessment is not required.
Pursuant to the Regulatory Flexibility
Act (5 U.S.C. chapter 6), it is hereby cer-
tified that the regulations will not have a
significant economic impact on a substan-
tial number of small entities. The only
provision that increases regulatory bur-
den is § 1.430(h)(3)-1(b), which generally
requires the use of generational mortality
tables. However, under § 1.430(h)(3)-1(c),
small entities are not required to use gen-
erational mortality tables. Therefore, these
regulations will not have a significant eco-
nomic impact on a substantial number of
small entities.
Section 202 of the Unfunded Mandates
Reform Act of 1995 requires that agencies
assess anticipated costs and benefits and
take certain other actions before issuing a
final rule that includes any Federal mandate
that may result in expenditures in any one
year by a State, local, or tribal government,
in the aggregate, or by the private sector,
of $100 million in 1995 dollars, updated
annually for inflation. These regulations do
not include any Federal mandate that may
result in expenditures by State, local, or
tribal governments, or by the private sector
in excess of that threshold.
Executive Order 13132 (Federalism)
prohibits an agency from publishing any
rule that has federalism implications if
the rule either imposes substantial, direct
compliance costs on State and local gov-
ernments, and is not required by statute,
or preempts State law, unless the agency
meets the consultation and funding
requirements of section 6 of the Executive
order. These regulations do not have fed-
eralism implications, impose substantial
direct compliance costs on State and local
governments, or preempt State law within
the meaning of the Executive order.
Pursuant to section 7805(f) of the
Code, the proposed regulations that pre-
ceded these regulations were submitted
to the Chief Counsel for Advocacy of
the Small Business Administration
for comment on their impact on small
business.
Pursuant to the Congressional Review
Act (5 U.S.C. 801 et seq.), the Office of
Information and Regulatory Affairs des-
ignated this rule as not a major rule, as
defined by 5 U.S.C. 804(2).
Drafting Information
The principal authors of these regu-
lations are Arslan Malik and Linda S. F.
Marshall of the Office of Associate Chief
Counsel (Employee Benefits, Exempt
Organizations, and Employment Taxes).
However, other personnel from the Treasury
Department and the IRS participated in the
development of these regulations.
List of Subjects in 26 CFR Part 1
Income taxes, Incorporation by ref-
erence, Reporting and recordkeeping
requirements.
Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.430(h)(3)-1 is revised
to read as follows:
§ 1.430(h)(3)-1 Mortality tables used to
determine present value.
(a) Overview—(1) Standard mortality
tables. This section sets forth rules for the
mortality tables to be used in determining
present value or making any computation
under section 430. These mortality tables
include—
(i) Generational mortality tables
described in paragraph (b) of this section;
and
(ii) Static mortality tables for small
plans described in paragraph (c) of this
section.
(2) Alternative tables—(i) Plan-
specific mortality tables. In lieu of using
the mortality tables provided under this
section, plan-specific substitute mortality
tables are permitted to be used for pur-
poses of section 430 pursuant to section
430(h)(3)(C), provided that the require-
ments of § 1.430(h)(3)-2 are satisfied.
(ii) Disabled individuals. In lieu of
using the mortality tables provided under
this section, mortality tables for disabled
individuals are permitted to be used pur-
suant to section 430(h)(3)(D). These
tables are provided in guidance published
in the Internal Revenue Bulletin. See §
601.601(d) of this chapter.
(3) Individuals not identified as either
male or female. The mortality tables in
this section are applied for an individual
based on the individual’s gender. With
respect to the portion of a plan’s popula-
tion for which male or female gender is not
identified (for example, because an indi-
vidual identifies as nonbinary or because
the gender information for an individual
is not available), the plan’s actuary must
use a reasonable approach for determining
liability. Some reasonable approaches for
these individuals include—

November 13, 2023 1242 Bulletin No. 2023–46
(i) Determining the liability for an indi-
vidual for whom male or female gender is
not identified as the weighted average of
the liability calculated as if the individual
were male and the liability calculated as if
the individual were female, with an appro-
priate weighting that takes into account
the distribution of gender for individuals
in the plan’s population for whom gender
is identified; and
(ii) Assigning either male or female
status randomly to an individual for whom
male or female gender is not identified
in a manner that is expected to result in
an appropriate proportion of males and
females for the plan’s population that
takes into account the distribution of gen-
der for individuals in the plan’s population
for whom gender is identified.
(b) Generational mortality tables—(1)
In general—(i) Construction of genera-
tional mortality tables. The generational
mortality tables that are permitted to be
used under section 430(h)(3)(A) and
paragraph (a)(1)(i) of this section are con-
structed from the base mortality tables
described in paragraph (b)(1)(ii) of this
section and the mortality improvement
rates described in paragraph (b)(1)(iii)
of this section, as adjusted in accordance
with paragraph (b)(1)(v) of this section.
(ii) Base mortality tables. The base
mortality tables are set forth in paragraph
(d) of this section.
(iii) Mortality improvement rates—(A)
Mortality improvement rates for valua-
tion dates occurring on or after January
1, 2024. Except as otherwise provided
in this paragraph (b)(1)(iii), the mortal-
ity improvement rates for valuation dates
occurring on or after January 1, 2024, are
the 2024 Adjusted Scale MP-2021 Rates
as incorporated by reference pursuant to
paragraph (b)(1)(iv)(A) of this section.
(B) [Reserved.]
(iv) Incorporation by reference. The
material listed in this paragraph (b)(1)
(iv) is incorporated by reference into this
section with the approval of the Director
of the Federal Register under 5 U.S.C.
552(a) and 1 CFR part 51. This material
is available for inspection at the IRS and
at the National Archives and Records
Administration (NARA). Contact IRS at:
IRS Office of Chief Counsel, Qualified
Plans Branch 1, CC:EEE:EB:QP1, 1111
Constitution Avenue NW, Washington,
DC 20224; (202) 317-6700; www.irs.
gov/retirement-plans/pension-plan-mor-
tality-tables. For information on the
availability of this material at NARA,
visit www.archives.gov/federal-register/
cfr/ibr-locations or email fr.inspection@
nara.gov. The material may be obtained
from IRS: www.irs.gov/retirement-plans/
pension-plan-mortality-tables.
(A) 2024 Adjusted Scale MP-2021
Rates, dated August 11, 2023.
(B) [Reserved]
(2) Application of mortality improve-
ment rates—(i) In general. Under the
generational mortality tables described in
this paragraph (b), the probability of an
individual’s death at a particular age in
the future is determined as the individu-
al’s base mortality rate that applies at that
age (that is, the applicable mortality rate
from the tables set forth in paragraph (d)
of this section for that age, gender, and
status as an annuitant or a non-annuitant)
multiplied by the cumulative mortality
improvement factor for the individual’s
gender and for that age for the period from
the base year for those mortality tables
through the calendar year in which the
individual is projected to reach the partic-
ular age. Paragraph (b)(3) of this section
provides an example that shows how the
base mortality tables in paragraph (d) of
this section and the mortality improve-
ment rates for valuation dates occurring
during 2024 are combined to determine
projected mortality rates.
(ii) Cumulative mortality improvement
factor. The cumulative mortality improve-
ment factor for an age and gender for a
period is the product of the annual mortal-
ity improvement factors for that age and
gender for each year within that period.
(iii) Annual mortality improvement
factor. The annual mortality improve-
ment factor for an age and gender for a
year is 1 minus the mortality improve-
ment rate that applies for that age and
gender for that year. If that annual mor-
tality improvement rate is greater than 1
(corresponding to a negative mortality
improvement rate), then the projected
mortality rate for that age and gender
for that year is greater than the projected
mortality rate for the same age and gen-
der for the preceding year.
(3) Example of calculation—(i) Calculation of
mortality rate. The mortality rate for 2024 that is
applied to a male annuitant who is age 68 in 2024 is
equal to the product of the mortality rate under para-
graph (d) of this section for a male annuitant who
was age 68 in 2012 (0.01418) and the cumulative
mortality improvement factor calculated from the
2024 Adjusted Scale MP-2021 Rates for an age 68
male from 2012 to 2024. The cumulative mortality
improvement factor for age 68 males for the period
from 2012 to 2024 is 0.9827, and the mortality rate
for 2024 for male annuitants who are age 68 in that
year is 0.01393, as shown in the following table.
Table 1 to paragraph (b)(3)(i)
Calendar
Year
Rate of Mortality
Improvement
from Prior Year to Current Year
Annual Mortality
Improvement
Factor (1- Mortality Improvement
Rate)
Cumulative
Mortality
Improvement
Factor
Mortality
Rate
2012n/an/an/a0.01418
20130.00710.99290.9929
20140.00470.99530.9882
20150.00290.99710.9854
20160.00170.99830.9837
20170.00090.99910.9828
20180.00010.99990.9827
2019(0.0001)1.00010.9828

Bulletin No. 2023–46 1243 November 13, 2023
Calendar
Year
Rate of Mortality
Improvement
from Prior Year to Current Year
Annual Mortality
Improvement
Factor (1- Mortality Improvement
Rate)
Cumulative
Mortality
Improvement
Factor
Mortality
Rate
20200.00010.99990.9827
20210.00001.00000.9827
20220.00001.00000.9827
20230.00001.00000.9827
20240.00001.00000.98270.01393
(ii) Probability of survival for an individ-
ual. After the projected mortality rates are derived
for each age for each year, the rates are used to
calculate the present value of a benefit stream that
depends on the probability of survival year-by-year.
For example, for purposes of calculating the present
value (for a 2024 valuation date) of future payments
in a benefit stream payable for a male annuitant who
is age 68 in 2024, the probability of survival for the
annuitant is based on the mortality rate for a male
annuitant who is age 68 in 2024 (0.01393), and the
projected mortality rate for a male annuitant who
will be age 69 in 2025 (0.01507), age 70 in 2026
(0.01635), and so on.
(4) Use of the tables—(i) Separate
tables for annuitants and non-annuitants.
Separate mortality tables are provided
for use with respect to annuitants and
non-annuitants. The non-annuitant mor-
tality tables are applied to determine the
probability of survival for a non-annuitant
for the period before the non-annuitant
is projected to commence receiving ben-
efits. The annuitant mortality tables are
applied to determine the present value of
benefits for each annuitant. In addition,
the annuitant mortality tables are applied
for each non-annuitant with respect to
each assumed commencement of ben-
efits for the period beginning with that
assumed commencement. For purposes
of this section, an annuitant means a plan
participant who has commenced receiv-
ing benefits and a non-annuitant means
a plan participant who has not yet com-
menced receiving benefits (for example,
an active employee or a terminated vested
participant). A participant whose benefit
has partially commenced is treated as an
annuitant with respect to the portion of the
benefit that has commenced and treated as
a non-annuitant with respect to the balance
of the benefit. In addition, with respect to
a beneficiary of a participant, the annui-
tant mortality tables apply for the period
beginning with each assumed commence-
ment of benefits for the participant. If the
participant has died (or to the extent the
participant is assumed to die before com-
mencing benefits), the annuitant mortality
tables apply with respect to the benefi-
ciary for the period beginning with each
assumed commencement of benefits for
the beneficiary.
(ii) Examples of calculation using sep-
arate non-annuitant and annuitant tables.
With respect to a 45-year-old active par-
ticipant who is projected to commence
receiving an annuity at age 55, the fund-
ing target is determined using the non-an-
nuitant mortality tables for the period
before the participant attains age 55 and
using the annuitant mortality tables for
the period ages 55 and above. Similarly,
for a 45-year-old terminated vested par-
ticipant who is projected to commence
an annuity at age 65, the funding target
is determined using the non-annuitant
mortality tables for the period before the
participant attains age 65 and using the
annuitant mortality tables for ages 65 and
above.
(c) Static mortality tables—(1)
Availability of alternative tables for small
plans—(i) In general. As an alternative to
the generational mortality tables defined
in paragraph (b) of this section, static
mortality tables may be used for a small
plan. The static mortality tables described
in this paragraph (c) are constructed from
the separate non-annuitant and annuitant
static mortality tables described in para-
graph (c)(2)(i) of this section, combined
using the procedure described in para-
graph (c)(2)(ii) of this section.
(ii) Definition of small plan. For pur-
poses of this paragraph (c), a small plan is
defined as a plan with 500 or fewer total
participants (including both active and
inactive participants and beneficiaries of
deceased participants) on the valuation
date.
(iii) Use of static mortality tables. The
static mortality tables that are used for
a valuation date are the static mortality
tables for the calendar year that includes
the valuation date.
(iv) Publication of mortality tables.
The static mortality tables for the 2024
calendar year are set forth in paragraph (e)
of this section.
Note 1 to paragraph (c)(1)(iv): The
static mortality tables for valuation dates
occurring in later calendar years will
be published in the Internal Revenue
Bulletin. See § 601.601(d) of this chapter.
(2) Development of static mortality
tables—(i) Non-annuitant and annui-
tant mortality tables. The non-annuitant
and annuitant static mortality tables are
determined using the base mortality tables
described in paragraph (b)(1)(ii) of this
section. The rates in those base mortal-
ity tables are adjusted using the mortality
improvement rates described in paragraph
(b)(1)(iii) of this section, in accordance
with the rules set forth in paragraph (c)(3)
of this section.
(ii) Combined static mortality tables.
The static mortality tables described in
this paragraph (c) are constructed from
the separate non-annuitant and annuitant
static mortality tables pursuant to para-
graph (c)(2)(i) of this section, blended
using the weighting factors in paragraph
(d) of this section. The weighting factors
are applied to develop these combined
static tables using the following equation:
Combined mortality rate = [non-annuitant
rate * (1- weighting factor)] + [annuitant
rate * weighting factor].
(3) Projection of mortality improve-
ments—(i) General rule. Except as pro-
vided in paragraph (c)(3)(iii) of this
section, the static mortality tables for a
calendar year are determined by multi-
plying the applicable mortality rate for

November 13, 2023 1244 Bulletin No. 2023–46
each age from the base mortality tables by
both—
(A) The cumulative mortality improve-
ment factor (determined under paragraph
(b)(2)(ii) of this section) for the period
from 2012 through that calendar year; and
(B) The cumulative mortality improve-
ment factor (determined under paragraph
(b)(2)(ii) of this section) for the period
beginning in that calendar year and con-
tinuing beyond that calendar year for the
number of years in the projection period
described in paragraph (c)(3)(ii) of this
section.
(ii) Projection period for static mortal-
ity tables—(A) In general. The projection
period is 8 years for males and 9 years
for females, as adjusted based on age as
provided in paragraph (c)(3)(ii)(B) of this
section.
(B) Age adjustment. For ages below
80, the projection period is increased by 1
year for each year below age 80. For ages
above 80, the projection period is reduced
(but not below zero) by ⅓ year for each
year above 80.
(iii) Fractional projection periods.
If for an age the number of years in the
projection period determined under para-
graph (c)(3)(ii) of this section is not a
whole number, then the mortality rate
for that age is determined by using linear
interpolation between—
(A) The mortality rate for that age that
would be determined under paragraph (c)
(3)(i) of this section if the number of years
in the projection period were the next
lower whole number; and
(B) The mortality rate for that age that
would be determined under paragraph (c)
(3)(i) of this section if the number of years
in the projection period were the next
higher whole number.
(iv) Example. For example, at age 85 the projec-
tion period for a male is 6⅓ years (8 years minus
⅓ year for each of the 5 years above age 80). For a
valuation date in 2024, the mortality rate in the static
mortality table for an 85-year-old male is based on
a projection of mortality improvement for 6⅓ years
beyond 2024. Under paragraph (c)(3)(iii) of this sec-
tion, the mortality rate for an 85-year-old male annu-
itant in the static mortality table for 2024 is ⅔ times
the projected mortality rate for a male annuitant that
age in 2030 plus ⅓ times the projected mortality rate
for a male annuitant that age in 2031. Accordingly,
the mortality rate for an 85-year-old male annuitant
in the static mortality table for 2024 is 0.08126 (⅔
times the projected mortality rate for an 85-year-
old male annuitant in 2030 (0.08146) plus ⅓ times
the projected mortality rate for an 85-year-old male
annuitant in 2031 (0.08086)).
(d) Base mortality tables. The following are the
base mortality tables. The base year for these tables
is 2012.
Table 2 to paragraph (d)
MalesFemales
AgeNon-AnnuitantAnnuitant
Weighting
Factor
For Small
PlansNon-AnnuitantAnnuitant
Weighting
Factor
For Small
Plans
00.006500.006500.00000.005440.005440.0000
10.000450.000450.00000.000380.000380.0000
20.000300.000300.00000.000230.000230.0000
30.000220.000220.00000.000180.000180.0000
40.000190.000190.00000.000130.000130.0000
50.000160.000160.00000.000120.000120.0000
60.000140.000140.00000.000110.000110.0000
70.000130.000130.00000.000100.000100.0000
80.000110.000110.00000.000090.000090.0000
90.000090.000090.00000.000090.000090.0000
100.000080.000080.00000.000090.000090.0000
110.000090.000090.00000.000090.000090.0000
120.000130.000130.00000.000100.000100.0000
130.000170.000170.00000.000120.000120.0000
140.000220.000220.00000.000130.000130.0000
150.000280.000280.00000.000130.000130.0000
160.000340.000340.00000.000140.000140.0000
170.000400.000400.00000.000150.000150.0000
180.000460.000460.00000.000150.000150.0000
190.000530.000530.00000.000150.000150.0000
200.000560.000560.00000.000150.000150.0000
210.000560.000560.00000.000150.000150.0000
220.000560.000560.00000.000160.000160.0000
230.000550.000550.00000.000180.000180.0000

Bulletin No. 2023–46 1245 November 13, 2023
MalesFemales
AgeNon-AnnuitantAnnuitant
Weighting
Factor
For Small
PlansNon-AnnuitantAnnuitant
Weighting
Factor
For Small
Plans
240.000550.000550.00000.000190.000190.0000
250.000540.000540.00000.000190.000190.0000
260.000540.000540.00000.000190.000190.0000
270.000540.000540.00000.000200.000200.0000
280.000540.000540.00000.000200.000200.0000
290.000540.000540.00000.000200.000200.0000
300.000550.000550.00000.000210.000210.0000
310.000550.000550.00000.000220.000220.0000
320.000560.000560.00000.000230.000230.0000
330.000580.000580.00000.000250.000250.0000
340.000590.000590.00000.000260.000260.0000
350.000610.000610.00000.000280.000280.0000
360.000630.000630.00000.000310.000310.0000
370.000650.000650.00000.000340.000340.0000
380.000680.000680.00000.000360.000360.0000
390.000710.000710.00000.000400.000400.0000
400.000740.000740.00000.000430.000430.0000
410.000770.000820.00080.000470.000490.0010
420.000810.000990.00160.000510.000610.0020
430.000860.001240.00240.000550.000780.0030
440.000910.001580.00320.000600.001010.0040
450.000970.002000.00400.000650.001300.0051
460.001050.002510.00470.000710.001650.0061
470.001130.003100.00550.000770.002060.0071
480.001230.003780.00630.000830.002520.0081
490.001340.004540.00710.000900.003040.0091
500.001470.005390.00790.000980.003620.0101
510.001610.005440.01400.001070.004260.0185
520.001770.005650.02090.001160.004950.0262
530.001940.005880.03020.001260.005000.0349
540.002130.006160.04300.001370.005120.0449
550.002340.006470.08980.001480.005170.0853
560.002570.006860.16760.001610.005220.1535
570.002810.007280.21530.001750.005280.1923
580.003080.007700.26350.001900.005610.2291
590.003380.008110.31440.002060.006010.2680
600.003690.008480.38210.002240.006430.3192
610.004030.008820.45790.002430.006900.3731
620.004410.009180.59350.002640.007430.4705
630.004810.009600.71530.002870.007960.5668
640.005250.010140.77640.003120.008590.6230
650.005730.010870.84540.003390.009280.7172
660.006360.011780.90020.003800.010030.8006
670.007060.012880.92750.004270.010890.8414
680.007840.014180.94310.004800.011920.8658
690.008700.015640.95470.005400.013090.8857

November 13, 2023 1246 Bulletin No. 2023–46
MalesFemales
AgeNon-AnnuitantAnnuitant
Weighting
Factor
For Small
PlansNon-AnnuitantAnnuitant
Weighting
Factor
For Small
Plans
700.009670.017290.96420.006060.014440.9046
710.010730.019140.97320.006810.015970.9240
720.011920.021210.97910.007650.017700.9365
730.013230.023540.98230.008600.019670.9437
740.014690.026130.98470.009660.021920.9512
750.016320.029050.98680.010850.024450.9568
760.018120.032330.98890.012190.027270.9637
770.020120.036040.99060.013700.030420.9682
780.022340.040260.99200.015390.033910.9727
790.024800.045040.99350.017290.037750.9765
800.027540.050461.00000.019430.041981.0000
810.029890.056571.00000.021340.046631.0000
820.034600.063431.00000.025160.051781.0000
830.041660.071141.00000.030890.057541.0000
840.051080.079771.00000.038530.064011.0000
850.062850.089461.00000.048080.071321.0000
860.076980.100321.00000.059550.079541.0000
870.093460.112481.00000.072930.088791.0000
880.112290.126001.00000.088220.099361.0000
890.133480.140881.00000.105420.111241.0000
900.157030.157031.00000.124530.124531.0000
910.174010.174011.00000.138180.138181.0000
920.191510.191511.00000.152500.152501.0000
930.209360.209361.00000.167370.167371.0000
940.227420.227421.00000.182740.182741.0000
950.245690.245691.00000.198630.198631.0000
960.264150.264151.00000.215090.215091.0000
970.282810.282811.00000.232140.232141.0000
980.301690.301691.00000.249830.249831.0000
990.320770.320771.00000.268140.268141.0000
1000.339960.339961.00000.286980.286981.0000
1010.359100.359101.00000.306190.306191.0000
1020.377940.377941.00000.325490.325491.0000
1030.396330.396331.00000.344720.344721.0000
1040.414150.414151.00000.363750.363751.0000
1050.431310.431311.00000.382430.382431.0000
1060.447710.447711.00000.400650.400651.0000
1070.463290.463291.00000.418280.418281.0000
1080.478000.478001.00000.435220.435221.0000
1090.491810.491811.00000.451390.451391.0000
1100.500000.500001.00000.466730.466731.0000
1110.500000.500001.00000.481200.481201.0000
1120.500000.500001.00000.494770.494771.0000
1130.500000.500001.00000.500000.500001.0000
1140.500000.500001.00000.500000.500001.0000
1150.500000.500001.00000.500000.500001.0000

Bulletin No. 2023–46 1247 November 13, 2023
MalesFemales
AgeNon-AnnuitantAnnuitant
Weighting
Factor
For Small
PlansNon-AnnuitantAnnuitant
Weighting
Factor
For Small
Plans
1160.500000.500001.00000.500000.500001.0000
1170.500000.500001.00000.500000.500001.0000
1180.500000.500001.00000.500000.500001.0000
1190.500000.500001.00000.500000.500001.0000
1201.000001.000001.00001.000001.000001.0000
(e) Static tables for 2024. The following static
mortality tables are used pursuant to paragraph
(a)(1)(ii) of this section for determining present
value or making any computation under section
430 with respect to valuation dates occurring
during 2024.
Table 3 to paragraph (e)
AgeMaleFemale
00.003560.00306
10.000250.00022
20.000170.00013
30.000120.00010
40.000110.00008
50.000090.00007
60.000080.00007
70.000080.00006
80.000060.00005
90.000050.00005
100.000050.00006
110.000050.00006
120.000080.00006
130.000100.00008
140.000130.00008
150.000170.00008
160.000210.00009
170.000250.00010
180.000290.00010
190.000340.00010
200.000360.00010
210.000370.00010
220.000370.00011
230.000380.00013
240.000390.00014
250.000400.00014
260.000410.00015
270.000430.00016
280.000440.00016
290.000460.00017
300.000490.00018
310.000500.00019
320.000530.00021

November 13, 2023 1248 Bulletin No. 2023–46
AgeMaleFemale
330.000560.00023
340.000590.00024
350.000620.00026
360.000650.00029
370.000670.00031
380.000700.00032
390.000720.00035
400.000740.00037
410.000750.00039
420.000770.00041
430.000790.00043
440.000810.00045
450.000840.00048
460.000880.00051
470.000920.00055
480.000980.00059
490.001040.00064
500.001130.00070
510.001240.00080
520.001370.00090
530.001530.00101
540.001730.00115
550.002060.00138
560.002530.00170
570.002960.00195
580.003440.00225
590.003970.00258
600.004580.00299
610.005230.00343
620.006150.00409
630.007030.00478
640.007740.00537
650.008610.00619
660.009570.00707
670.010540.00786
680.011630.00871
690.012830.00968
700.014190.01082
710.015750.01217
720.017500.01368
730.019490.01540
740.021750.01742
750.024330.01975
760.027290.02240
770.030690.02540
780.034600.02878
790.039120.03254
800.044420.03715
810.050080.04158

Bulletin No. 2023–46 1249 November 13, 2023
AgeMaleFemale
820.056490.04650
830.063720.05202
840.071920.05823
850.081260.06527
860.091800.07337
870.103640.08255
880.116880.09305
890.131480.10480
900.147330.11790
910.164040.13141
920.181110.14547
930.198470.16007
940.215880.17495
950.233190.19020
960.251520.20655
970.270100.22354
980.288990.24127
990.308360.25965
1000.327880.27862
1010.347420.29799
1020.366720.31750
1030.385740.33705
1040.404360.35650
1050.421910.37576
1060.438970.39452
1070.455200.41279
1080.470640.43024
1090.485360.44694
1100.494480.46282
1110.495520.47794
1120.496560.49215
1130.497560.49820
1140.498700.49900
1150.499750.49980
1160.499900.49990
1170.499950.50000
1180.500000.50000
1190.500000.50000
1201.000001.00000
(f) Applicability date. This section
applies for valuation dates occurring on or
after January 1, 2024.
Par. 3. Section 1.430(h)(3)-2 is
amended by:
a. In paragraph (c)(3)(ii) deleting the
text “§ 1.430(h)(3)-1(a)(2)(i)(E)” and
adding in its place Ҥ 1.430(h)(3)-1(b)(2)
(ii)”;
b. Revising paragraph (c)(6)(ii)(E); and
c. In paragraph (d)(4)(iii)(A):
i. Deleting the text Ҥ 1.430(h)(3)-
1(a)(2)(i)(E)” and adding in its place “§
1.430(h)(3)-1(b)(2)(ii)”;
ii. Deleting “2006” and adding in its
place “2012”; and
iii. Deleting the text Ҥ 1.430(h)(3)-
1(a)(2)(i)(C)” and adding in its place “§
1.430(h)(3)-1(b)(1)(iii).”
The revision reads as follows:
§ 1.430(h)(3)-2 Plan-specific substitute
mortality tables used to determine
present value.
*****
(c) ***
(6) ***
(ii) ***
(E) The date specified in guidance pub-
lished in the Internal Revenue Bulletin (see

November 13, 2023 1250 Bulletin No. 2023–46
§ 601.601(d) of this chapter) in conjunc-
tion with a replacement of mortality tables
specified under section 430(h)(3)(A) and
§ 1.430(h)(3)-1 (other than changes to
the mortality improvement rates under §
1.430(h)(3)-1(b)(1)(iii) or annual updates
to the static mortality tables issued as
noted in § 1.430(h)(3)-1(c)(1)(iv)).
*****
Par. 4. Section 1.431(c)(6)-1 is revised
to read as follows:
§ 1.431(c)(6)-1 Mortality tables used to
determine current liability.
(a) Mortality tables used to determine
current liability. In accordance with sec-
tion 431(c)(6)(D), the mortality assump-
tions that apply to a single-employer
defined benefit plan for the plan year pur-
suant to section 430(h)(3)(A) and (D) and
§§ 1.430(h)(3)-1(a)(1) and (a)(2)(ii) are
used to determine a multiemployer plan’s
current liability for purposes of applying
the rules of section 431(c)(6). For pur-
poses of this paragraph (a), either the gen-
erational mortality tables used pursuant to
§ 1.430(h)(3)-1(b) or the static mortality
tables used pursuant to § 1.430(h)(3)-1(c)
are permitted to be used without regard to
whether the plan is a small plan. However,
substitute mortality tables under §§
1.430(h)(3)-1(a)(2)(i) and 1.430(h)(3)-2
are not permitted to be used for purposes
of this paragraph (a).
(b) Applicability date. This section
applies for valuation dates occurring on or
after January 1, 2024.
Par. 5. Section 1.433(h)(3)-1 is revised
to read as follows:
§ 1.433(h)(3)-1 Mortality tables used to
determine current liability.
(a) Mortality tables used to determine
current liability. In accordance with sec-
tion 433(h)(3)(B), the mortality assump-
tions that apply to a single-employer
defined benefit plan for the plan year
pursuant to section 430(h)(3)(A) and (D)
and §§ 1.430(h)(3)-1(a)(1) and (a)(2)(ii)
are used to determine a cooperative and
small employer charity (CSEC) plan’s
current liability under section 433(h). For
purposes of this paragraph (a), either the
generational mortality tables used pursu-
ant to § 1.430(h)(3)-1(b) or the static mor-
tality tables used pursuant to § 1.430(h)
(3)-1(c) are permitted to be used without
regard to whether the plan is a small plan
as defined in § 1.430(h)(3)-1(c)(1)(ii).
However, substitute mortality tables under
§§ 1.430(h)(3)-1(a)(2)(i) and 1.430(h)
(3)-2 are not permitted to be used for pur-
poses of this paragraph (a).
(b) Applicability date. This section
applies for valuation dates occurring on or
after January 1, 2024.
Douglas W. O’Donnell,
Deputy Commissioner for Services and
Enforcement.
Approved: October 4, 2023.
Lily L. Batchelder,
Assistant Secretary of the Treasury
(Tax Policy).
(Filed by the Office of the Federal Register October
19, 2023, 8:45 a.m., and published in the issue of the
Federal Register for October 20, 2023, 88 FR 72357)

Bulletin No. 2023–46 1251 November 13, 2023
Part IV
Deletions From
Cumulative List
of Organizations,
Contributions to Which
are Deductible Under
Section 170 of the Code
Announcement 2023-31
The Internal Revenue Service has
revoked its determination that the organi-
zations listed below qualify as organiza-
tions described in sections 501(c)(3) and
170(c)(2) of the Internal Revenue Code of
1986.
Generally, the IRS will not disallow
deductions for contributions made to a
listed organization on or before the date
of announcement in the Internal Revenue
Bulletin that an organization no longer
qualifies. However, the IRS is not pre-
cluded from disallowing a deduction for
any contributions made after an organiza-
tion ceases to qualify under section 170(c)
(2) if the organization has not timely filed
a suit for declaratory judgment under sec-
tion 7428 and if the contributor (1) had
knowledge of the revocation of the ruling
or determination letter, (2) was aware that
such revocation was imminent, or (3) was
in part responsible for or was aware of the
activities or omissions of the organization
that brought about this revocation.
If on the other hand a suit for declar-
atory judgment has been timely filed,
contributions from individuals and orga-
nizations described in section 170(c)(2)
that are otherwise allowable will continue
to be deductible. Protection under sec-
tion 7428(c) would begin on November
13, 2023 and would end on the date the
court first determines the organization is
not described in section 170(c)(2) as more
particularly set for in section 7428(c)(1).
For individual contributors, the maximum
deduction protected is $1,000, with a hus-
band and wife treated as one contributor.
This benefit is not extended to any indi-
vidual, in whole or in part, for the acts or
omissions of the organization that were
the basis for revocation.
NAME OF ORGANIZATIONEffective Date
Of Revocation
LOCATION
ST. JOHNS HOUSE LEARNING AND
DEVELOPMENT CENTER INC
08/01/2020HUNTINGTON, WEST VIRGINIA
VILLAGERS FOR TRUMP INC12/31/2019THE VILLAGE, FL
UNISON DUET MUSIC PRODUCTION INC09/19/2018GLENDALE, CA

November 13, 2023 1252 Bulletin No. 2023–46
Notice of Proposed
Rulemaking
Plan-Specific Substitute
Mortality Tables for
Determining Present Value
REG-103525-23
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Notice of proposed rulemaking.
SUMMARY: This document sets forth
proposed regulations that would update
the requirements that a plan sponsor of a
single-employer defined benefit plan must
meet to obtain IRS approval to use mor-
tality tables specific to the plan in calcu-
lating present value for minimum funding
purposes (as a substitute for the generally
applicable mortality tables). These regu-
lations would affect participants in, ben-
eficiaries of, employers maintaining, and
administrators of certain retirement plans.
DATES: Written or electronic comments
and requests for a public hearing must be
received by December 19, 2023.
ADDRESSES: Commenters are strongly
encouraged to submit public comments
electronically. Submit electronic submis-
sions via the Federal eRulemaking Portal
at www.regulations.gov (indicate IRS and
REG-103525-23) by following the online
instructions for submitting comments.
Requests for a public hearing must be
submitted as prescribed in the “Comments
and Requests for a Public Hearing” sec-
tion. Once submitted to the Federal
eRulemaking Portal, comments cannot be
edited or withdrawn. The Department of
the Treasury (Treasury Department) and
the IRS will publish for public availabil-
ity any comments submitted to the IRS’s
public docket. Send paper submissions to:
CC:PA:LPD:PR (REG-103525-23), room
5203, Internal Revenue Service, PO Box
7604, Ben Franklin Station, Washington,
DC 20044.
FOR FURTHER INFORMATION
CONTACT: Concerning the regulations,
Arslan Malik or Linda S. F. Marshall at
(202) 317-6700 (not a toll-free number);
concerning submissions of comments
and requests for a public hearing, Vivian
Hayes at (202) 317-6901 (not a toll-free
number) or by sending an email to publi-
chearings@irs.gov (preferred).
SUPPLEMENTARY INFORMATION:
Background
Section 412 of the Internal Revenue
Code (Code) prescribes minimum funding
requirements for defined benefit pension
plans. Section 430 specifies the minimum
funding requirements that apply generally
to defined benefit plans that are single-em-
ployer plans (that is, not multiemployer
plans).
1
For a plan subject to section
430, section 430(a) defines the minimum
required contribution for a plan year by
reference to the plan’s funding target for
the plan year. Under section 430(d)(1), a
plan’s funding target for a plan year gen-
erally is the present value of all benefits
accrued or earned under the plan as of the
first day of that plan year.
Section 430(h)(3) provides rules
regarding the mortality tables to be used
under section 430. Under section 430(h)
(3)(A), except as provided in section
430(h)(3)(C) or (D), the Secretary is to
prescribe by regulation mortality tables to
be used in determining any present value
or making any computation under section
430. Section 430(h)(3)(C) prescribes rules
for a plan sponsor’s use of substitute mor-
tality tables reflecting the specific mor-
tality experience of a plan’s population
instead of using the generally applicable
mortality tables. Under section 430(h)
(3)(C), the plan sponsor may request the
Secretary’s approval to use plan-specific
substitute mortality tables that meet
requirements specified in the statute. If the
Secretary determines that the proposed
tables meet the statutory standards and
approves the request, the substitute mor-
tality tables are used to determine present
values and make computations under sec-
tion 430 during the period of consecutive
plan years (not to exceed 10) specified in
the request.
Under section 430(h)(3)(C)(iii), a sub-
stitute mortality table may be used for a
plan only if: (1) the plan has a sufficient
number of plan participants and has been
maintained for a sufficient period of time
to have credible mortality information
necessary to create a substitute mortality
table; and (2) the table reflects the actual
mortality experience of the plan’s par-
ticipants and projected trends in general
mortality experience. Except as provided
by the Secretary, a plan sponsor may not
use substitute mortality tables for any
plan unless substitute mortality tables are
established and used for each plan main-
tained by the plan sponsor or a member of
its controlled group.
Final regulations (TD 9826) under
section 430(h)(3) were published in the
Federal Register on October 5, 2017 (82
FR 46388). The final regulations issued
in 2017 include rules regarding gener-
ally applicable mortality tables, which
are set forth in §1.430(h)(3)-1 (the 2017
general mortality table regulations), as
well as rules regarding substitute mortal-
ity tables, which are set forth in §1.430(h)
(3)-2 (the 2017 substitute mortality table
regulations). The 2017 substitute mortal-
ity table regulations provide that any sub-
stitute mortality tables must be based on
the plan’s mortality experience during an
experience study period that consists of 2,
3, 4, or 5 consecutive 12-month periods. In
conjunction with the 2017 substitute mor-
tality table regulations, the Department of
the Treasury (Treasury Department) and
the IRS issued Rev. Proc. 2017-55, 2017-
43 IRB 373, which sets forth the procedure
by which a plan sponsor of a defined ben-
efit plan may request and obtain approval
1
Section 302 of the Employee Retirement Income Security Act of 1974, Pub. L. No. 93-406, 88 Stat. 829 (1974), as amended (ERISA), sets forth funding rules that are parallel to those in
section 412 of the Code, and section 303 of ERISA sets forth additional funding rules for defined benefit plans (other than multiemployer plans) that are parallel to those in section 430 of the
Code. Pursuant to section 101 of Reorganization Plan No. 4 of 1978, 5 U.S.C. App., as amended, the Secretary of the Treasury has interpretive jurisdiction over the subject matter addressed
in these proposed regulations for purposes of ERISA, as well as the Code. Thus, these proposed Treasury regulations issued under section 430 of the Code would also apply for purposes of
section 303 of ERISA.

Bulletin No. 2023–46 1253 November 13, 2023
for the use of plan-specific substitute mor-
tality tables.
Beginning in 2020 and extending into
2023, for many pension plans, the mortal-
ity experience of the plan participants was
significantly higher than expected due to
the COVID-19 pandemic. The Treasury
Department and the IRS are concerned
that, if a plan sponsor applied for approval
of plan-specific substitute mortality tables
using an experience study period that
reflects the actual mortality experience for
the plan’s population during those years,
then the existing rules and procedures
used for generating those tables would
result in plan-specific substitute mortality
tables that overstate the expected future
mortality for the plan’s population. This
is because substitute mortality tables are
constructed based on a mortality ratio cal-
culated for the plan’s population, which
is determined by dividing the actual mor-
tality experience for plan participants
during the experience study period by the
expected mortality under the generally
applicable mortality tables. In the absence
of any changes to the rules and procedures
for generating plan-specific substitute
mortality tables, a mortality ratio devel-
oped using an experience study period that
includes the period in which the COVID-
19 pandemic occurred (COVID-19 pan-
demic period) will likely be unusually
high, as the numerator of the mortality
ratio (the plan’s actual experience) will
reflect the actual number of deaths during
this period, while the denominator of that
ratio (the expected deaths for the plan
population) will be based on the expected
number of deaths from the generally
applicable mortality tables (which reflect
only a small fraction of the significant
short-term increase in mortality rates that
occurred during the COVID-19 pandemic
period).
The Treasury Department and the IRS
are issuing final regulations updating
the generally applicable mortality tables
under section 430(h)(3)(A) (TD 9983) in
the Rules and Regulations section of this
issue of the Federal Register. Those final
regulations adopt mortality tables that are
based on the mortality tables in the Pri-
2012 Private Retirement Plans Mortality
Tables Report (Pri-2012),
2
which were
developed using the mortality experience
for private sector pension plans during
the period from 2010 to 2014. In light of
the fact that the Pri-2012 mortality tables
did not reflect any mortality experience
from the COVID-19 pandemic period,
the preamble to the proposed regulations
that preceded those final regulations asked
for comments about whether the rules and
procedures relating to development of
substitute mortality tables should be mod-
ified to recognize the potential that the
mortality experience for the COVID-19
pandemic period is not accurately predic-
tive of the future mortality experience for
participants of a plan for which substitute
mortality tables are requested. In response,
commenters suggested various solutions
that included: (1) excluding mortality data
from the COVID-19 pandemic period, (2)
applying a reduced weight to the mortal-
ity data from the COVID-19 pandemic
period in developing the substitute mor-
tality tables, (3) extending the duration
of the experience study period (which has
a similar effect of reducing the weight of
the mortality data for that period), and (4)
computing the mortality ratio for a sub-
stitute mortality table by comparing pre-
2020 data to the Pri-2012 base mortality
table and post-2019 data to the Pri-2012
base mortality table (as projected) with a
specified load.
Explanation of Provisions
These proposed regulations would
generally retain the methodology for
development of substitute mortality tables
included in the 2017 substitute mortality
table regulations but provide additional
rules regarding the use of mortality expe-
rience data for the COVID-19 pandemic
period. In order to develop a mortality
ratio that is more accurately predictive of
future mortality experience for a plan pop-
ulation, these proposed regulations would
provide that the expected deaths for the
plan population used in determining the
denominator in the mortality ratio are cal-
culated by adjusting the mortality rates in
the generally applicable mortality tables.
Specifically, the proposed regulations
would provide that, for each 12-month
period that is included in the experience
study period and that begins after 2019
and before 2024, the expected mortal-
ity rate for an individual is determined
by multiplying the expected mortality
rate for that individual from the standard
mortality tables by an adjustment factor.
3

The adjustment factor for each of these
years would approximate the ratio (as
reported by the National Center for Health
Statistics, which is part of the Centers for
Disease Control and Prevention)
4
of (1)
the actual number of deaths for the general
population for the year to (2) the expected
number of deaths for the general popula-
tion for that year.
Applicability Date
The proposed regulations are proposed
to apply for plan years beginning on or
after January 1, 2025.
Statement of Availability of IRS
Documents
IRS Revenue Rulings, Revenue
Procedures, and Notices cited in this docu-
ment are published in the Internal Revenue
Bulletin (or Cumulative Bulletin) and
are available from the Superintendent of
Documents, U.S. Government Publishing
Office, Washington, DC 20402, or by vis-
iting the IRS website at www.irs.gov.
Special Analyses
Pursuant to the Memorandum
of Agreement, Review of Treasury
Regulations under Executive Order 12866
(June 9, 2023), tax regulatory actions
issued by the IRS are not subject to the
requirements of section 6 of Executive
Order 12866, as amended. Therefore,
2
The Pri-2012 Report can be found at: https://www.soa.org/49c106/globalassets/assets/files/resources/experience-studies/2019/pri-2012-mortality-tables-report.pdf.
3
This approach is similar to the fourth approach suggested by commenters, as described in the Background section of this preamble because a direct adjustment to the expected mortality
rates during the COVID-19 pandemic period would be more appropriate than calculating mortality ratios using an approach that either ignores the mortality experience during the COVID-19
pandemic period or reduces the weighting of that experience.
4
https://www.cdc.gov/nchs/nvss/vsrr/covid19/excess_deaths.htm

November 13, 2023 1254 Bulletin No. 2023–46
a regulatory impact assessment is not
required.
It is hereby certified that this proposed
rule will not have a significant economic
impact on a substantial number of small
entities. Small employers generally can-
not use plan-specific substitute mortality
tables because their defined benefit pen-
sion plans do not have credible mortality
experience (which is defined as a mini-
mum number of deaths during the expe-
rience study period) as is required to use
substitute mortality tables. Therefore, a
regulatory flexibility analysis under the
Regulatory Flexibility Act is not required.
Pursuant to section 7805(f) of the Code,
these proposed regulations will be sub-
mitted to the Chief Counsel for Advocacy
of the Small Business Administration for
comment on their impact on small business.
Section 202 of the Unfunded Mandates
Reform Act of 1995 requires that agencies
assess anticipated costs and benefits and
take certain other actions before issuing a
final rule that includes any Federal man-
date that may result in expenditures in
any one year by a State, local, or Tribal
government, in the aggregate, or by the
private sector, of $100 million in 1995
dollars, updated annually for inflation.
The proposed regulations do not propose
any rule that would include any Federal
mandate that may result in expenditures
by State, local, or Tribal governments,
or by the private sector in excess of that
threshold.
Executive Order 13132 (Federalism)
prohibits an agency from publishing any
rule that has federalism implications if
the rule either imposes substantial, direct
compliance costs on State and local gov-
ernments, and is not required by statute,
or preempts State law, unless the agency
meets the consultation and funding
requirements of section 6 of the Executive
order. The proposed regulations do not
propose rules that would have federalism
implications, impose substantial direct
compliance costs on State and local gov-
ernments, or preempt State law within the
meaning of the Executive order.
Comments and Requests for a Public
Hearing
Consideration will be given to com-
ments that are submitted timely to the
IRS as prescribed in the preamble under
the ADDRESSES section. The Treasury
Department and the IRS request com-
ments on all aspects of these proposed
regulations. Any comments submitted will
be made available at www.regulations.gov
or upon request.
A public hearing will be scheduled if
requested in writing by any person who
timely submits electronic or written com-
ments. Requests for a public hearing are
also encouraged to be made electronically.
If a public hearing is scheduled, notice of
the date and time for the public hearing
will be published in the Federal Register.
Drafting Information
The principal authors of these regu-
lations are Arslan Malik and Linda S. F.
Marshall of the Office of Associate Chief
Counsel (Employee Benefits, Exempt
Organizations, and Employment Taxes).
However, other personnel from Treasury
and the IRS participated in the develop-
ment of these regulations.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Proposed Amendments to the
Regulations
Accordingly, the Treasury Department
and the IRS propose to amend 26 CFR
part 1 as follows:
PART 1--INCOME TAXES
Paragraph 1. The authority citation for
part 1 continues to read, in part, as follows:
Authority: 26 U.S.C. 7805 * * *
Par. 2. Section 1.430(h)(3)-2 is
amended by:
a. In paragraph (a) removing Ҥ
601.601(d)(2)(ii)(b)” and adding in its
place “§ 601.601(d)”;
b. In paragraph (d)(2)(ii)(B) removing
the text “January 1, 2019 year is” and add-
ing in its place the text “January 1, 2019
is”;
c. Revising paragraph (d)(4)(iii)(A).
d. Redesignating paragraph (d)(4)(iii)
(B) as paragraph (d)(4)(iii)(C) and adding
a new paragraph (d)(4)(iii)(B).
e. Revising paragraph (g).
The additions and revisions read as
follows:
§1.430(h)(3)-2 Plan-specific substitute
mortality tables used to determine
present value.
* * * * *
(d) * * *
(4) * * *
(iii) * * *
(A) Projection of base table. Except as
otherwise provided in this paragraph (d)
(4)(iii), the standard mortality table for a
year is the mortality table determined by
applying cumulative mortality improve-
ment factors determined under §1.430(h)
(3)-1(b)(2)(ii) to the base mortality table
under §1.430(h)(3)-1(d) for the period
beginning with the base year for that mor-
tality table and ending in the base year
for the base substitute mortality table
determined under paragraph (c)(3)(ii) of
this section. For purposes of the preced-
ing sentence, the cumulative mortality
improvement factors are determined using
the mortality improvement rates described
in §1.430(h)(3)-1(b)(1)(iii) that apply for
the calendar year during which the plan
sponsor submits the request for approval
to use substitute mortality tables.
(B) Adjustments to standard mortality
table for 2020, 2021, 2022, and 2023. If
a 12-month period in the experience study
period begins after December 31, 2019,
and before January 1, 2024, the probabil-
ity of death for an individual under para-
graph (d)(4)(ii)(A)(2)(i) of this section is
determined as the mortality rate for the
individual’s age (at the beginning of the
year) and gender from the standard mor-
tality table determined under paragraph
(d)(4)(iii) of this section multiplied by the
adjustment factor in Table 1 for the cal-
endar year that includes the first day of
the 12-month period. For example, for an
experience study period that begins April
1, 2019, and ends March 31, 2023, the
probability of death for the year begin-
ning April 1, 2022, for a male annuitant
who is age 65 as of that date is the prob-
ability of death from the base mortality
table (0.01087), multiplied by the cumu-
lative mortality improvement factor for
the period from 2012 to 2021 (1.02292)
and by the adjustment factor for the 2022

Bulletin No. 2023–46 1255 November 13, 2023
calendar year of 1.10, resulting in a proba-
bility of death of 0.01223.
Table 1 to paragraph (d)(4)(iii)(B):
Calendar YearAdjustment Factor
20201.15
20211.15
20221.10
20231.05
* * * * *
(g) Applicability date--(1) General
rule. This section applies for plan years
beginning on or after January 1, 2025.
Except as provided in paragraph (g)(2) of
this section, the substitute mortality table
used for a plan for such a plan year must
comply with the rules of paragraphs (a)
through (f) of this section.
(2) Transition rule for previously
approved substitute mortality tables. If a
plan sponsor has received approval from
the Commissioner to use substitute mor-
tality tables for a plan year beginning
in 2025, then the plan’s base substitute
mortality tables that were approved are
treated as satisfying the requirements of
paragraph (d) or (e) of this section, as
applicable.
Douglas W. O’Donnell,
Deputy Commissioner for Services and
Enforcement.
(Filed by the Office of the Federal Register October
19, 2023, 8:45 a.m., and published in the issue of the
Federal Register for October 20, 2023, 88 FR 72409)

Bulletin No. 2023–46 i November 13, 2023
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion. It
is not used where a position in a prior rul-
ing is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

November 13, 2023 ii Bulletin No. 2023–46
Numerical Finding List
1
Bulletin 2023–46
Announcements:
2023-18, 2023-30 I.R.B. 366
2023-19, 2023-30 I.R.B. 367
2023-20, 2023-30 I.R.B. 368
2023-17, 2023-31 I.R.B. 412
2023-21, 2023-31 I.R.B. 413
2023-22, 2023-32 I.R.B. 429
2023-23, 2023-34 I.R.B. 569
2023-24, 2023-35 I.R.B. 661
2023-25, 2023-37 I.R.B. 821
2023-26, 2023-37 I.R.B. 822
2023-28, 2023-37 I.R.B. 823
2023-29, 2023-41 I.R.B. 1064
2023-30, 2023-45 I.R.B. 1236
2023-31, 2023-46 I.R.B. 1251
Notices:
2023-29, 2023-29 I.R.B. 1
2023-45, 2023-29 I.R.B. 317
2023-47, 2023-29 I.R.B. 318
2023-37, 2023-30 I.R.B. 359
2023-50, 2023-30 I.R.B. 361
2023-51, 2023-30 I.R.B. 362
2023-54, 2023-31 I.R.B. 382
2023-53, 2023-32 I.R.B. 424
2023-55, 2023-32 I.R.B. 427
2023-57, 2023-34 I.R.B. 560
2023-58, 2023-34 I.R.B. 563
2023-59, 2023-34 I.R.B. 564
2023-52, 2023-35 I.R.B. 650
2023-61, 2023-35 I.R.B. 651
2023-62, 2023-37 I.R.B. 817
2023-56, 2023-38 I.R.B. 824
2023-63, 2023-39 I.R.B. 919
2023-64, 2023-40 I.R.B. 974
2023-66, 2023-40 I.R.B. 992
2023-68, 2023-41 I.R.B. 1060
2023-65, 2023-42 I.R.B. 1067
2023-67, 2023-42 I.R.B. 1074
2023-69, 2023-42 I.R.B. 1079
2023-71, 2023-44 I.R.B. 1191
2023-70, 2023-45 I.R.B. 1228
2023-72, 2023-45 I.R.B. 1228
2023-73, 2023-45 I.R.B. 1232
Proposed Regulations:
REG-124123-22, 2023-30 I.R.B. 369
REG-124930-21, 2023-31 I.R.B. 431
REG-120730-21, 2023-33 I.R.B. 491
REG-134420-10, 2023-34 I.R.B. 571
REG-109348-22, 2023-35 I.R.B. 662
REG-120727-21, 2023-36 I.R.B. 670
REG-122793-19, 2023-38 I.R.B. 829
Proposed Regulations:—Continued
REG-100908-23, 2023-39 I.R.B. 931
REG-115559-23, 2023-42 I.R.B. 1082
REG-106203-23, 2023-43 I.R.B. 1143
REG-113064-23, 2023-43 I.R.B. 1144
REG-117614-14, 2023-44 I.R.B. 1193
REG-127391-16, 2023-44 I.R.B. 1214
REG-103525-23, 2023-46 I.R.B. 1252
Revenue Procedures:
2023-31, 2023-25 I.R.B. 386
2023-26, 2023-33 I.R.B. 486
2023-27, 2023-35 I.R.B. 655
2023-17, 2023-37 I.R.B. 819
2023-30, 2023-40 I.R.B. 995
2023-31, 2023-40 I.R.B. 1057
2023-32, 2023-41 I.R.B. 1064
2023-35, 2023-42 I.R.B. 1079
2023-28, 2023-43 I.R.B. 1092
2023-33, 2023-43 I.R.B. 1135
Revenue Rulings:
2023-13, 2023-32 I.R.B. 413
2023-14, 2023-33 I.R.B. 484
2023-15, 2023-34 I.R.B. 559
2023-15, 2023-34 I.R.B. 559
2023-16, 2023-37 I.R.B. 796
2023-17, 2023-37 I.R.B. 798
2023-18, 2023-40 I.R.B. 972
2023-19, 2023-41 I.R.B. 1059
2023-20, 2023-45 I.R.B. 1221
Treasury Decisions:
9976, 2023-30 I.R.B. 354
9977, 2023-31 I.R.B. 375
9978, 2023-32 I.R.B. 415
9979, 2023-35 I.R.B. 602
9980, 2023-43 I.R.B. 1087
9981, 2023-44 I.R.B. 1174
9982, 2023-45 I.R.B. 1223
9983, 2023-46 I.R.B. 1237
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 27, 2023.

Bulletin No. 2023–46 iii November 13, 2023
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2023–46
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2023–27 through 2023–52 is in Internal Revenue Bulletin
2023–52, dated December 27, 2023.

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