SECTION 1. PURPOSE

This revenue procedure provides a safe harbor concerning the application of §§ 7702 and 7702A of the Internal Revenue Code (the “Code”) to life insurance contracts that (1) have mortality guarantees based upon prevailing commissioners’ standard tables ² that extend beyond age 100, such as the 2001 Commissioners’ Standard Ordinary Mortality Tables (“2001 CSO tables”) and the 2017 Commissioners’ Standard Ordinary Mortality Tables (“2017 CSO tables”), and (2) may continue in force after the day on which the insured individual (“the insured”) attains age 100. This revenue procedure modifies and supersedes Rev. Proc. 2010– 28, 2010–34 I.R.B. 270, to provide for application of the safe harbor described in Rev. Proc. 2010–28 to life insurance contracts that have mortality guarantees based

upon not only the 2001 CSO tables, but also upon the 2017 CSO tables and any other prevailing commissioners’ standard tables that extend beyond age 100.