Memo #
33560

ICI Letter to Treasury/IRS Recommending Retirement Plan Items for Priority Guidance Plan
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[33560]

June 1, 2021

TO: ICI Members
Pension Committee
Pension Operations Advisory Committee SUBJECTS: Pension
Tax RE: ICI Letter to Treasury/IRS Recommending Retirement Plan Items for Priority Guidance Plan

 

ICI submitted the attached letter requesting that the Treasury Department and Internal Revenue Service include guidance on certain issues concerning retirement security on their 2021-2022 Priority Guidance Plan.[1] ICI submitted a separate letter with recommendations concerning regulated investment companies and their shareholders.

The letter asks for guidance on several provisions of the SECURE Act,[2] including:

  • Post-death required minimum distribution rules for designated beneficiaries;
  • Qualified birth/adoption distributions;
  • Pooled Employer Plans and the unified plan rule;
  • Consolidated Form 5500 reporting for groups of similar plans; and
  • Updated LRMs and Forms for IRA providers to reflect SECURE Act changes.

Other items in the letter relate to:

  • Permanence of remote notarization relief;
  • Final regulations under Code section 411(a)(11);
  • Expansion of EPCRS self-correction; and
  • Waivers of inadvertent violations of the one-per-year limit on IRA rollovers.

 

Elena Barone Chism
Associate General Counsel - Retirement Policy

 

endnotes

[1] Notice 2021-28 requests public submissions for possible inclusion on the original 2021-2022 Priority Guidance Plan. Notice 2021-28 is available at https://www.irs.gov/pub/irs-drop/n-21-28.pdf.

[2] For more background on the SECURE Act, see ICI Memorandum No. 32118, dated December 20, 2019 available at https://www.ici.org/my_ici/memorandum/memo32118.

    Attachments

    33560a.pdf