Memo #
29894

ICI Draft Recommendations for 2016-2017 Treasury/IRS Priority Guidance Plan -- Retirement Plan Items
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ACTION REQUESTED

[29894]

May 5, 2016

TO:

PENSION COMMITTEE No. 2-16
PENSION OPERATIONS ADVISORY COMMITTEE No. 2-16

RE:

ICI DRAFT RECOMMENDATIONS FOR 2016-2017 TREASURY/IRS PRIORITY GUIDANCE PLAN -- RETIREMENT PLAN ITEMS

 

Notice 2016-26 invites public comment on recommendations for Treasury’s 2016-2017 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 16, 2016.

Attached for your review is a draft letter requesting the inclusion of several guidance projects on the 2016-2017 Priority Guidance Plan, all of which we requested in prior letters to the IRS and Treasury. [2] These include additional guidance on 403(b) plan terminations and 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. 

Please let us know if you have suggestions for additional recommendations or if you believe any of our recommendations should be removed from the letter.  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) by close of business on Thursday, May 12, 2016.

 

Elena Barone Chism
Associate General Counsel

 

Attachment

 

endnotes

[1] Notice 2016-26 is available at http://www.irs.gov/pub/irs-drop/n-16-26.pdf

[2] For a copy of the Institute’s recommendations for the 2015-2016 Priority Guidance Plan, see Memorandum to Pension Members No. 16-15 [28956], dated May 5, 2015.  The 2015-2016 Priority Guidance Plan is available at http://www.irs.gov/pub/irs-utl/2015-2016_pgp_2nd_quarter_update.pdf (items related to retirement benefits appear on pages 4-7).