[13175]
February 20, 2001
TO: PENSION COMMITTEE No. 12-01
PENSION OPERATIONS ADVISORY COMMITTEE No. 16-01
AD HOC COMMITTEE ON RMD REFORM
RE: INSTITUTE DRAFT COMMENT LETTER ON PROPOSED REGULATIONS ON RMDS
Attached is a first draft of the Institute’s comment letter on the Internal Revenue
Service’s proposed regulations on required minimum distributions.1 Please note that this letter
is an early draft and it outlines the issues we intend to raise in our comment letter to the Service
regarding the proposed regulations. As a result of our conference call on the proposed
regulations held on January 31, we were able to determine general types of issues that would
require clarification by the Service. We have divided the comment letter into three sections in
response to the issues raised on the conference call – IRA trustee reporting requirements,
transition issues and proposed regulations Q&As.
In the IRA trustee reporting requirements section, we address the problems that IRA
trustees would face in reporting annual RMD amounts to their shareholders. We also propose
an alternative approach to the reporting requirement –one that would add date of birth
information to the Form 1040, and include a worksheet to help the taxpayer calculate his RMD
for the year. This section includes various examples of information that is troublesome for IRA
trustees to obtain and maintain accurately. Please provide us comments regarding these
examples, particularly data and other information to support the position that this information
is difficult to obtain and maintain.
1 See Institute Memorandum to Pension Members No. 2-01 and Pension Operations Advisory Committee No. 3-01,
dated January 17, 2001.
2In both the transition issues and proposed regulations Q&As section, we have listed
areas that appear preliminarily to be issues under the proposed regulations. For many of these
issues we require further comment from you regarding our recommendations to the Service.
We also welcome comments concerning additional issues not included in the letter.
Please review this draft letter and provide comments to me via email at ricard@ici.org or
by fax at (202) 326-5841 or by calling me at (202) 218-3563 by COB Thursday, March 1, 2001.
Kathryn A. Ricard
Associate Counsel
Attachment
Attachment (in .pdf format)