[10529]
December 3, 1998
TO: PENSION COMMITTEE No. 82-98
PENSION OPERATIONS ADVISORY COMMITTEE No. 67-98
TRANSFER AGENT ADVISORY COMMITTEE No. 81-98
AD HOC COMMITTEE ON ROTH IRA
OCTOBER 22 ROTH IRA MEETING ATTENDEES
RE: INSTITUTE FILES COMMENT LETTER ON ROTH IRA GUIDANCE
______________________________________________________________________________
The Institute has filed a comment letter on the proposed regulations with respect to Roth IRA
issues and Internal Revenue Service Notices 98-49 and 98-50. With respect to Notice 98-49, the
Institute commented on the following issues: recharacterization transaction reporting requirements,
Internal Revenue Service reporting alternatives for recharacterization transactions, Service-approved
Roth IRA documents and reporting conversion transactions involving withholding. With respect to
Notice 98-50, the Institute requested guidance on the issue of partial recharacterizations. Finally, with
respect to the proposed regulations, the Institute requested clarification on the following issues:
recharacterization by beneficiaries, withholding rules applicable to recharacterizations, minimum
required distributions and the surviving spouse, decedents who die during the 4-year spread for 1998
conversions and conversions of SIMPLE IRAs.
A copy of the comment letter is attached.
Kathryn Ricard
Assistant Counsel
Attachment