ICI Draft Recommendations for 2014-2015 Treasury/IRS Priority Guidance Plan - Retirement Plan Items

URGENT/ACTION REQUESTED

[28036]

April 14, 2014

TO: PENSION COMMITTEE No. 11-14
PENSION OPERATIONS ADVISORY COMMITTEE No. 9-14 RE: ICI DRAFT RECOMMENDATIONS FOR 2014-2015 TREASURY/IRS PRIORITY GUIDANCE PLAN -- RETIREMENT PLAN ITEMS

 

Notice 2014-18 invites public comment on recommendations for Treasury’s 2014-2015 Priority Guidance Plan. [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, 2014.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2014-2015 Priority Guidance Plan, 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 Priority Guidance Plan. [2] 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 25, 2014.

 

Elena Barone Chism
Associate Counsel

Attachment

endnotes

[1] Notice 2014-18 is available at http://www.irs.gov/pub/irs-drop/n-14-18.pdf.

[2] For a copy of the Institute’s recommendations for the 2013-2014 Priority Guidance Plan, see Memorandum to Pension Members No. 20-13 [27210], dated May 1, 2013. The 2013-2014 Priority Guidance Plan is available at http://www.irs.gov/pub/irs-utl/2013-2014_pgp_2nd_quarter_update.pdf (items related to retirement benefits appear on pages 5-8).