Systems Retirement 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 subject to administrative review by the corporation. Any new determination made by the corporation under this section shall be governed by the same administrative review process as any other benefit determination by the corporation. (b) Trust fund for payment of increased benefits (1) Establishment There is established in the Treasury of the United States a trust fund to be known as the Delphi Full Vested Plan Benefit Trust Fund (hereafter in this subsection referred to as the Fund ), consisting of such amounts as may be appropriated or credited to the Fund as provided in this section. (2) Funding There is appropriated from the general fund such amounts as are necessary for the costs of the payment of the portion of monthly benefits guaranteed to a participant or beneficiary pursuant to subsection (a) and for necessary administrative and operating expenses of the corporation relating to such payment. The Fund shall be credited with amounts from time to time as the Secretary of the Treasury, in conjunction with the Director of the corporation, determines appropriate, from the general fund of the Treasury. (3) Expenditures from Fund Amounts in the Fund shall be available for the payment of the portion of monthly benefits guaranteed to a participant or beneficiary pursuant to subsection (a) and for necessary administrative and operating expenses of the corporation relating to such payment. (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 (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),