Memo #
34174

ICI Letter to Treasury/IRS Recommending Retirement Plan Items for Priority Guidance Plan
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[34174]

June 3, 2022

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 2022-2023 Priority Guidance Plan.[1] ICI submitted a separate letter with recommendations concerning regulated investment companies and their shareholders.

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

  • Post-death required minimum distribution rules for designated beneficiaries;[3]
  • Qualified birth/adoption distributions;
  • The unified plan rule for multiple employer plans;[4] and
  • Updated LRMs and model 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 2022-21 requests public submissions for possible inclusion on the original 2022-2023 Priority Guidance Plan. Notice 2022-21 is available at https://www.irs.gov/pub/irs-drop/n-22-21.pdf.

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

[3] For our recent comment letter on Treasury's proposed regulations on required minimum distributions, see ICI Memorandum No. 34160, dated May 25, 2022, available at: https://www.ici.org/memo34160.

[4] For our recent comment letter on Treasury's proposed regulations implementing the unified plan rule exception, see ICI Memorandum No. 34164, dated May 27, 2022, available at: https://www.ici.org/memo34164.

    Attachments

    34174a.pdf