(F) The Delphi Mechatronic Systems Re-
tirement Program. 
(5) TREATMENT OF PBGC DETERMINATIONS.— 
Any determination made by the corporation under 
this section concerning a recalculation of benefits or 
lump-sum payment of past-due benefits shall be sub-
ject to administrative review by the corporation. Any 
new determination made by the corporation under 
this section shall be governed by the same adminis-
trative review process as any other benefit deter-
mination by the corporation. 
(b) FUNDING FOR PAYMENT OF INCREASED BENE-
FITS.—The costs of any payment for the portion of 
monthly benefits guaranteed to a participant or bene-
ficiary pursuant to subsection (a) and necessary adminis-
trative and operating expenses of the corporation relating 
to such payment shall be paid using amounts derived from 
the unobligated balance of the fund established under sec-
tion 4005 of ERISA with respect to basic benefits guaran-
teed under section 4022 of ERISA. 
(c) REGULATIONS.—The corporation, in consultation 
with the Secretary of the Treasury and the Secretary of 
Labor, may issue such regulations as necessary to carry 
out this section. 
(d) TAX TREATMENT OF LUMP-SUM PAYMENTS.— 
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(1) IN GENERAL.—Unless the taxpayer elects 
(at such time and in such manner as the Secretary 
may provide) to have this paragraph not apply with 
respect to any lump-sum payment under subsection 
(a)(2)(B), the amount of such payment shall be in-
cluded in the taxpayer’s gross income ratably over 
the 3-taxable-year period beginning with the taxable 
year in which such payment is received. 
(2) SPECIAL RULES RELATED TO DEATH.— 
(A) IN GENERAL.—If the taxpayer dies be-
fore the end of the 3-taxable-year period de-
scribed in paragraph (1), any amount to which 
paragraph (1) applies which has not been in-
cluded in gross income for a taxable year end-
ing before the taxable year in which such death 
occurs shall be included in gross income for 
such taxable year. 
(B) SPECIAL
ELECTION
FOR
SURVIVING 
SPOUSES OF ELIGIBLE PARTICIPANTS.—If— 
(i) a taxpayer with respect to whom 
paragraph (1) applies dies, 
(ii) such taxpayer is an eligible partic-
ipant, 
(iii) the surviving spouse of such eligi-
ble participant is entitled to a survivor 
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benefit from the corporation with respect 
to such eligible participant, and 
(iv) such surviving spouse elects (at 
such time and in such manner as the Sec-
retary may provide) the application of this 
subparagraph, 
subparagraph (A) shall not apply and any 
amount which would have (but for such tax-
payer’s death) been included in the gross in-
come of such taxpayer under paragraph (1) for 
any taxable year beginning after the date of 
such death shall be included in the gross in-
come of such surviving spouse for the taxable 
year of such surviving spouse ending with or 
within such taxable year of the taxpayer. 
(e) AMENDMENT TO SECTION 4005 OF ERISA.— 
Section 4005(b)(2)(A) of the Employee Retirement In-
come Security Act of 1974 (29 U.S.C. 1305(b)(2)(A)) is 
amended by inserting after ‘‘4022’’ the following: ‘‘(in-
cluding any portion of monthly benefits guaranteed pursu-
ant to section 2(a) of the Delphi Retirees Pension Restora-
tion Act)’’. 
Æ 
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