Smart Benefits: Imputed Income for Group Term Life Insurance

Rob Calise, GoLocalProv Business/Health Expert

Smart Benefits: Imputed Income for Group Term Life Insurance

While employees are not generally taxed on the value of employer-provided benefits for the employee and his or her dependents, there are important exceptions to this rule. One such exception is for certain circumstances under which the cost of group term life insurance is imputed income to employees and thus is included as taxable income.

The federal tax code excludes the cost of the first $50,000 in group term life insurance coverage that an employer provides to an employee. All participants will have imputed income on premiums for group life insurance in excess of $50,000, if the policy is carried directly or indirectly by the employer. A policy is considered to be carried by the employer if:

the employer pays any part of the premiums (this includes premiums paid on a pre-tax basis by employees); or
the cost of the coverage for tax purposes – as determined by the IRS – is higher than the premium than an insurer charges.

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IRS regulations include a table of rates for calculating the cost of excess group term life insurance for tax purposes:

Determining the Amount of Income to Impute

If an employer pays the premiums for all of an employee’s group life insurance coverage, determining the amount to impute is easy:  subtract $50,000 from the total group term life insurance coverage in effect for the employee during the year and multiply the remaining amount of by applicable Table I rate. If the employer does not pay all the premiums, but the employee’s contributions are made on a pre-tax basis, this same calculation applies.

If the employee pays all or part of the premium for any group term life insurance coverage (including the first $50,000) on an after-tax basis, an additional calculation is needed.  After finding the Table I cost of all coverage above $50,000, as described above, deduct from that amount all of the employee’s after-tax contributions toward the coverage (including coverage under $50,000). If the result is a positive number, that is the amount to impute.
 
Sample Imputed Income Calculation

An employee is 42 years old and earns $38,000 annually.  The employer offers a term life benefit of 3x salary, to which the employee contributes $2.50 per month on an after-tax basis towards the cost.

The employee’s life insurance benefit is $114,000.  The value of the amount on which the employee must pay taxes is $64,000 ($114,000 - $50,000).  To calculate imputed income, $64,000 is divided by $1,000 (since table I rates are per thousand), then multiplied by $0.10 (the Table I rate for a 42 year old).  The result is $6.40 per month, less the employee’s contribution of $2.50, returns imputed income of $3.90 per month, or $46.80 per year for this employee.

W-2 Reporting and FICA Taxes

As taxable income, the imputed amount must be included in the employee’s taxable income reported on Form W-2, but the employer is not required to withhold for the employee’s federal income tax liability.  FICA taxes apply, however, and the employer must withhold the employee’s portion of FICA taxes.  The employer must also pay its portion of FICA taxes, and remit both the employer and employee FICA amounts.  For 2017, the Social Security tax rate is 6.2% on annual pay up to $127,200.  The Medicare tax rate is 1.45%, without a maximum limit.

Rob Calise is the Managing Director, Employee Benefits. of Cornerstone|Gencorp, where he helps clients control the costs of employee benefits by focusing on consumer driven strategies and on how to best utilize the tax savings tools the government provides. Rob serves as Chairman of the Board of United Benefit Advisors, and is a board member of the Blue Cross & Blue Shield of RI Broker Advisory Board, United HealthCare of New England Broker Advisory Board and Rhode Island Business Healthcare Advisors Council. He is also a member of the National Association of Health Underwriters (NAHU), American Health Insurance Association (AHIA) and the Employers Council on Flexible Compensation (ECFC), as well as various human resource associations. Rob is a graduate of Bryant University with a BS in Finance. 

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