Delta Pilots Disability and Survivorship Trust

“The trust is intended to qualify pursuant to section 501(c)(9) of the internal revenue code (the "code") and accordingly, the trust's net investment income is exempt from income taxes. The trust has obtained a favorable tax opinion letter from the internal revenue service ("irs") dated february 10, 1988. The trust has been amended since receiving the opinion letter. The trust must operate in accordance with the code to maintain the trust's tax exempt status. The company believes that the trust, as amended, continues to qualify and to operate in accordance with applicable requirements of the code, therefore, no provision for income taxes has been included.”

“The other liability amount noted here encompasses the incurred but not paid/reported disability benefit amounts as reported per the audited financial statements.”

“Accounting principles generally accepted in the united states of america requires management to evaluate tax positions taken and recognize a tax liability (or asset) if an uncertain position has been taken that more likely than not would not be sustained upon examination by the irs. Delta air lines, inc. (the "plan sponsor") analyzed tax positions taken by the delta pilots disability and survivorship plan (the "plan"), whose assets are held in the trust, and has concluded that as of june 30, 2020, there are no uncertain positions taken or expected to be taken that would require recognition of a liability (or asset) or disclosure in the financial statements. The plan is subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress.”

“The "other" amount is an adjustment to the total expenses and losses per the audited financial statements and is the difference between the current year and prior year incurred but not paid/reported disability benefit amounts. Benefits payable - current year 27,840,862 benefits payable - prior year -26,319,131 total to schedule d, part xii, line 4b 1,521,731”