Where Should Group Term Life Insurance Be Reported?

Group-term life insurance coverage provided under a policy carried directly or indirectly by an employer is excluded from taxes if the total amount does not exceed $50,000, as per IRC section 79. However, if the coverage exceeds $50,000, the imputed cost of coverage must be included in income and is subject to social security and Medicare taxes.

A policy is considered carried directly or indirectly by the employer if:

• The determination of whether the premium charges straddle the costs is based on the IRS Premium Table rates, not the actual cost.
• The employer subsidizes and/or redistributes the premium cost through its role.

A taxable fringe benefit arises if coverage exceeds $50,000 and the policy is considered carried directly or indirectly by the employer. If there is more than one policy from the same insurer, a combined test is used to determine whether it is carried directly or indirectly by the employer. However, policies can be tested separately if the costs and coverage can be clearly allocated between the two policies.

If coverage is provided by more than one insurer, each policy must be tested separately to determine whether it is carried directly or indirectly by the employer. The cost of employer-provided group-term life insurance on the life of an employee’s spouse or dependent, paid by the employer, is not taxable to the employee if the face amount of the coverage does not exceed $2,000. This coverage is excluded as a de minimis fringe benefit.

Example 1: All employees for Employer X are in the 40 to 44 year age group. The employer pays the full cost of the insurance. If at least one employee is charged more than the IRS Premium Table rate, and at least one is charged less, the coverage is considered carried by the employer. Therefore, each employee is subject to social security and Medicare tax on the cost of coverage over $50,000.

Example 2: All employees are charged the same rate, which is set by the third-party insurer. The employer pays nothing toward the cost. It does not matter what the rate is if the employer does not subsidize the cost or redistribute it between employees.

Example 3: A 47-year old employee receives $40,000 of coverage per year under a policy carried directly or indirectly by her employer. She is also entitled to $100,000 of optional insurance at her own expense. This amount is also considered carried by the employer. The cost of $10,000 of this amount is excludable; the cost of the remaining $90,000 is included in income.

It is important to understand the tax consequences of group term life insurance coverage provided by an employer to avoid any issues with reporting and taxes.