Memo #
28892

ICI Draft Recommendations for 2015-2016 Treasury/IRS Priority Guidance Plan -- Retirement Plan Items
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ACTION REQUESTED

[28892]

April 14, 2015

TO: PENSION COMMITTEE No. 6-15
PENSION OPERATIONS ADVISORY COMMITTEE No. 4-15 RE: ICI DRAFT RECOMMENDATIONS FOR 2015-2016 TREASURY/IRS PRIORITY GUIDANCE PLAN - RETIREMENT PLAN ITEMS

 

Notice 2015-27 invites public comment on recommendations for Treasury’s 2015-2016 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, 2015.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2015-2016 Priority Guidance Plan, including additional guidance on 403(b) plan terminations and the tax treatment of escheated amounts from retirement plans and IRAs. These guidance requests were also included in the Institute’s recommendations for the 2014-2015 Priority Guidance Plan. [2] This year’s letter also seeks additional guidance relating to the one-per-year limit on IRA rollovers. Specifically, the letter recommends that IRS issue guidance regarding waivers of inadvertent violations of the one-per-year limit on IRA rollovers in circumstances where the inadvertent violations are beyond the control of the IRA holder. Additionally, the letter requests guidance on the potential application of the one-per-year limit on IRA rollovers to Coverdell Education Savings Accounts.

The draft letter includes only retirement security items; the Institute will submit a separate letter with recommendations regarding regulated investment companies. If you have any comments on the draft, please contact Elena Chism at 202/326-5821 (elena.chism@ici.org) or Howard Bard at 202/326-5810 (howard.bard@ici.org) by close of business on Friday, April 24, 2015.

 

Elena Barone Chism
Associate General Counsel

Howard Bard
Assistant General Counsel

Attachment

endnotes

[1] Notice 2015-27 is available at http://www.irs.gov/pub/irs-drop/n-15-27.pdf.

[2] For a copy of the Institute’s recommendations for the 2014-2015 Priority Guidance Plan, see Memorandum to Pension Members No. 16-14 [28078], dated April 30, 2014. The 2014-2015 Priority Guidance Plan is available at http://www.irs.gov/pub/irs-utl/2014-2015_pgp_2nd_quarter_update.pdf (items related to retirement benefits appear on pages 5-8).