A proposed regulation was going to change the mortality table used to a pre/post RP-2000 table with improvements. Was this regulation ever finalized to anyone's knowledge??

The proposed regulation indicated that the improvements would be 15 years for nonannuitants and 7 years for annuitants. However, when looking at the factors in the proposed regulations it appears to be using 22 years and 14 years.

I am attempting to contact IRS and determine whether there is a glitch or I am just performing the calculations (and matching their numbers by the way) in a fashion not intended.

Thanks for any and all comments.

The mortality improvements of 7 and 15 years noted are to be projected from the end of the plan year of the valuation, not from 2000. Since the proposed effctive date was to be 2007, you would be projecting from 2000 to 2007, then for 7 or 15 more years. When measured from 2000, you would be using 14 and 22 years of improvements.