ICI Draft Recommendations for 2011-2012 Treasury/IRS Guidance Priority List - Retirement Plan Items

 

ACTION REQUESTED

[25161]

May 3, 2011

TO: PENSION COMMITTEE No. 16-11
PENSION OPERATIONS ADVISORY COMMITTEE No. 11-11 RE: ICI DRAFT RECOMMENDATIONS FOR 2011-2012 TREASURY/IRS GUIDANCE PRIORITY LIST - RETIREMENT PLAN ITEMS

 

Notice 2011-39 invites public comment on recommendations for Treasury’s 2011-2012 Guidance Priority List. [1]; The Institute plans to submit a letter recommending retirement plan items to be included on the list by the Notice’s deadline of June 1, 2011. [2]

Attached for your review is a draft Institute letter requesting the inclusion of several guidance projects on the 2011-2012 Guidance Priority List, including guidance resolving the treatment of partial rollovers of distributions containing both after-tax and pre-tax amounts and guidance on terminating 403(b) plans funded through individual custodial accounts. The attached letter includes only retirement security items; the Institute will submit a separate letter with recommendations regarding regulated investment companies.

If you have comments on this draft, please contact the undersigned at 202/326-5821 or Elena.Chism@ici.org by the close of business on Tuesday, May 24, 2011.

 

Elena Barone Chism
Associate Counsel

Attachment

endnotes

 [1] Notice 2011-39 is available at http://www.irs.gov/pub/irs-drop/n-11-39.pdf.

 [2] For a copy of the Institute’s recommendations for the 2010-2011 Guidance Priority List, see Memorandum to Pension Members No. 21-10 [24359], dated June 11, 2010. The 2010-2011 Priority Guidance Plan is available at http://www.irs.gov/pub/irs-utl/2010-2011_pgp.pdf (items relating to retirement benefits appear on pages 4 through 6).