Memo #
1247
CORRECTION OF IRS NOTICE CONCERNING REPORTING OF RECHARACTERIZED EXCESS CONTRIBUTIONS
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July 5, 1989
TO: PENSION MEMBERS NO. 31-89
RE: CORRECTION OF IRS NOTICE CONCERNING REPORTING OF
RECHARACTERIZED EXCESS CONTRIBUTIONS
__________________________________________________________
As we previously reported, IRS Notice 89-32 describes the
reporting requirements for corrective distributions under changes
to the Code by the Technical and Miscellaneous Revenue Act of
1988 (TAMRA). (See Institute Memorandum to Pension Members No.
15-89, dated March 14, 1989.) In attached Announcement 89-69,
the IRS has corrected Notice 89-32 with respect to the reporting
of recharacterized excess contributions.
As corrected, the notice provides that recharacterized
excess contributions must be reported on Form W-2P for the
taxable year in which a corrective distribution would have
occurred but for the recharacterization. The original notice
stated that such amounts must be reported in the taxable year in
which the employee's earliest elective contribution during the
plan year would have been received by the employee had he elected
to receive the amounts in cash.
We will keep you informed of further developments.
Kathy D. Ireland
Assistant General Counsel
Attachment