401(h) Basics

Life Insurance in a Money Purchase Plan: The Incidental Benefit Rules

Did you know certain retirement plans can hold life insurance? Discover how Money Purchase Plans (MPPs) can incorporate life insurance while adhering to IRS incidental benefit rules.

By 401h.com EditorialPublished Jun 20, 2026Updated Jun 20, 20263 min read

Key takeaways

  • Life insurance can be held within a Money Purchase Plan (MPP), but strict IRS incidental benefit rules apply.
  • The incidental benefit rule ensures that life insurance remains a secondary benefit, not the primary focus of the MPP.
  • Premiums for whole life policies are subject to the 100-times rule, while universal life and term policies follow the 25% rule.
  • Proper structuring of life insurance in an MPP can offer significant tax advantages and asset protection.
  • High-income earners and business owners may find this strategy beneficial for comprehensive financial planning.

What is a Money Purchase Plan (MPP)?

A Money Purchase Plan (MPP) is a type of defined contribution retirement plan. Unlike a 401(k), MPPs require employers to make mandatory, fixed contributions each year to their employees' accounts. These contributions are a percentage of an employee's compensation, set forth in the plan document.

While traditional 401(k)s offer more flexibility in contribution amounts, MPPs are known for their predictability and the security of guaranteed employer contributions. This structure can be particularly appealing to business owners looking for consistent, tax-advantaged savings for themselves and their employees. Learn more about Money Purchase Plans on 401h.com.

The Incidental Benefit Rule: A Key Consideration

The Internal Revenue Service (IRS) allows qualified retirement plans, including MPPs, to provide certain incidental benefits, such as life insurance. However, the term "incidental" is crucial here. The IRS mandates that the primary purpose of a qualified plan must be to provide retirement benefits, not life insurance.

The incidental benefit rule exists to prevent retirement plans from becoming de facto insurance schemes, which would undermine their tax-deferred status and intended purpose. Adhering to these rules is vital for maintaining the plan's qualified status and avoiding penalties.

How Life Insurance Can Be Held in an MPP

Incorporating life insurance into a Money Purchase Plan can offer unique advantages, especially for high-income individuals and business owners. The premiums for the life insurance policy are paid with pre-tax dollars from the plan, and the cash value can grow tax-deferred within the plan.

Upon the participant's death, the death benefit — or a portion of it, depending on the policy type and plan distribution — can be paid to beneficiaries. This can provide a significant financial safety net for families and can be particularly useful in estate planning strategies.

Types of Policies and Their Incidental Limits

The incidental benefit rule differentiates between various types of life insurance policies when held within an MPP. The limits are designed to ensure that the cost of the insurance remains a small fraction of the total plan contributions or benefits.

Two primary rules are applied depending on the type of policy:

  • **100-Times Rule (for Whole Life Policies):** For whole life insurance, the death benefit generally cannot exceed 100 times the expected monthly retirement benefit.
  • **25% Rule (for Universal Life and Term Policies):** For universal life and term life policies, the aggregate premiums paid for the life insurance cannot exceed 25% of the employer's cumulative contributions to the plan for that participant. This rule also applies to half of the premiums for whole life insurance.

Advantages of Combining Life Insurance and MPPs

For many, particularly business owners and highly compensated individuals, integrating life insurance into a Money Purchase Plan offers notable benefits:

  • Tax-Advantaged Premiums: Premiums are paid with pre-tax dollars, reducing current taxable income.
  • Tax-Deferred Growth: The cash value of permanent life insurance policies can grow tax-deferred within the plan.
  • Asset Protection: In many states, assets held within qualified retirement plans, including life insurance cash values, enjoy protection from creditors.
  • Estate Planning: Life insurance held within a plan can be a powerful tool for estate liquidity and wealth transfer, often bypassing probate and providing tax-efficient distributions to beneficiaries.

It's crucial to consult with a financial advisor and tax professional to ensure that this strategy aligns with your overall financial goals and complies with all IRS regulations.

Staying Compliant with IRS Regulations

Navigating the complexities of the incidental benefit rule and other IRS regulations is paramount when holding life insurance in an MPP. Failure to comply can lead to severe consequences, including disqualification of the plan, taxes on distributions, and penalties.

Plan administrators and participants must regularly monitor contributions and premium payments to ensure they remain within the prescribed limits. Keeping accurate records and seeking expert guidance are essential steps to maintain compliance and leverage the full benefits of this strategy. 401h.com offers insights into advanced retirement planning strategies.

Frequently asked questions

While various types of life insurance, including whole life, universal life, and term life, can be held in an MPP, specific incidental benefit rules apply differently to each type. It is essential to understand these distinctions.

Availability, tax treatment, and plan design depend on the facts and circumstances of the employer, plan document, participant group, and applicable law. 401h.com provides general educational information only — not tax, legal, actuarial, investment, or ERISA advice. Consult qualified tax, legal, actuarial, and plan professionals.

4E

401h.com Editorial

401h.com

The 401h.com editorial team publishes plain-English explainers on 401(h) retiree medical benefit plans. Educational only — not tax, legal, actuarial, investment, or ERISA advice.

Next step

Find out whether a 401(h) strategy may fit

Talk with a 401(h) specialist about your plan, participant group, and retiree medical objectives.

Availability, tax treatment, and plan design depend on the facts and circumstances of the employer, plan document, participant group, and applicable law. 401h.com provides general educational information only — not tax, legal, actuarial, investment, or ERISA advice. Consult qualified tax, legal, actuarial, and plan professionals.