Memo #
27196

ICI Draft Recommendations for 2013-2014 Treasury/IRS Guidance Priority List -- Retirement Plan Items
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URGENT/ACTION REQUESTED

[27196]

April 18, 2013

TO: PENSION COMMITTEE No. 9-13
PENSION OPERATIONS ADVISORY COMMITTEE No. 9-13 RE: ICI DRAFT RECOMMENDATIONS FOR 2013-2014 TREASURY/IRS GUIDANCE PRIORITY LIST -- RETIREMENT PLAN ITEMS

 

Notice 2013-22 invites public comment on recommendations for Treasury’s 2013-2014 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 May 1, 2013.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2013-2014 Guidance Priority List, including guidance resolving the treatment of partial rollovers of distributions containing both after-tax and pre-tax amounts.  The letter is largely based on our past recommendations for the annual Guidance Priority List, [2] with the addition of a request for guidance implementing section 902 of the American Taxpayer Relief Act of 2012, which allows in-plan Roth conversions of otherwise non-distributable amounts. [3]  The draft 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 Friday, April 26, 2013.

 

Elena Barone Chism
Associate Counsel

Attachment

[1] Notice 2013-22 is available at http://www.irs.gov/pub/irs-drop/n-13-22.pdf.

[2] For a copy of the Institute’s recommendations for the 2012-2013 Guidance Priority List, see Memorandum to Pension Members No. 19-12 [26115], dated May 2, 2012.  The 2012-2013 Priority Guidance Plan is available at http://www.irs.gov/pub/irs-utl/2012-2013_pgp_2nd_quarter_update.pdf (items related to retirement benefits appear on pages 4-8).

[3] See Memorandum to Pension Committee No. 3-13 and Pension Operations Advisory Committee No. 3-13 [27014], dated February 14, 2013.