That doesn't exactly address the issue. Here is a hypothetical situation. A man has been diagnosed with brain cancer, and thanks to medicine and a certain medical futility, he lives for longer than five years. In the sixth year, perhaps even the seventh year, while he is dying in a hospice, he loses his rights. His life expectancy is limited to five years from a tax standpoint.
We can resolve the issue by removing the five-year requirement. We would say that we simply acknowledge the doctor's certificate stating that the individual has a critical illness that could sooner or later be fatal. No doctor would have a hard time signing that kind of a document. That way, in terms of taxes, we would do away with any obligation to die within five years.
It would be ridiculous for individuals receiving palliative care, who need their money to pay for additional or private care, such as the services of a caregiver, to lose their income, pursuant to tax laws, because they are not dead within five years. I think that it's completely unreasonable to set a deadline for dying in revenue law.