[12214]
July 11, 2000
TO: PENSION COMMITTEE No. 46-00
PENSION OPERATIONS ADVISORY COMMITTEE No. 48-00
AD HOC COMMITTEE ON ROTH IRAS
RE: ICI DRAFT COMMENT LETTER ON NOTICE 2000-30
As you are aware, the Internal Revenue Service recently released guidance on Roth IRA
recharacterization reporting in Notice 2000-30.∗ Attached is a draft comment letter that the Institute
intends to submit to the Service concerning this recent guidance. Specifically, the Institute asks that the
Service clarify that IRA trustees and custodians (1) are responsible for reporting Roth IRA
recharacterization transactions that occur only within their own financial institution; and (2) may rely on
taxpayer information for purposes of coding the year of the recharacterization for Form 1099-R purposes
and for reporting earnings information on Form 5498. In addition, we request that the Service provide
guidance on what code (“N” or “R”) IRA trustees and custodians should use as a default code on Form
1099-R in circumstances where a taxpayer does not provide information concerning the year of a
particular recharacterization.
Please forward your comments to me on the Institute Roth IRA recharacterization
comment letter via fax at (202) 326-5841, email at ricard@ici.org or by phone at (202) 218-3563 by
COB Friday July 21, 2000. If you have any questions concerning the guidance, please call me at (202)
218-3563.
Kathryn A. Ricard
Associate Counsel
Attachment
Attachment (in .pdf format)
∗ See Institute Memorandum to Pension Committee No. 30-00 and Pension Operations Advisory Committee No. 39-00, dated
June 5, 2000.