ICI Recommends Retirement Security Items for Inclusion in the Treasury/IRS 2024-2025 Priority Guidance Plan

[35731]

June 04, 2024

TO: ICI Members
Pension Committee
Pension Operations Advisory Committee SUBJECTS: Pension
Tax RE: ICI Recommends Retirement Security Items for Inclusion in the Treasury/IRS 2024-2025 Priority Guidance Plan

 

ICI submitted the attached letter to Treasury and IRS on May 31, 2024, recommending items for inclusion in the 2024-2025 Priority Guidance Plan. In addition to incorporating the guidance requests previously submitted as a follow-up to the enactment of the SECURE 2.0 Act[1] and in response to IRS Notice 2024-02 (the SECURE 2.0 Act "grab-bag" guidance) (both included as attachments to the letter), we also requested that the following topics be included in the Priority Guidance Plan:

• Additional guidance under the Employee Plans Compliance Resolution System;[2]
• Roth treatment of certain catch-up contributions under SECURE 2.0 Act section 603;
• The unified plan rule for multiple employer plans;[3]
• Permanent remote notarization relief;[4]
• The notice requirement under Internal Revenue Code section 411(a)(11); and
• Application of the one-per-year limit on IRA rollovers.

 

David Cohen
Associate General Counsel, Retirement Policy
 

Notes

[1] For a discussion of the SECURE 2.0 Act, see ICI Memorandum No. 34795, dated January 12, 2023, available at www.ici.org/memo34795.

[2] For our comment letter on interim guidance under SECURE 2.0 Act section 305, see ICI Memorandum No. 35377, dated July 18, 2023, available at https://www.ici.org/memo35377.

[3] For our 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.

[4] For a discussion of the December 2022 proposal to make permanent the temporary relief from the physical presence requirement, see ICI Memorandum No. 34806, dated Jan. 13, 2023, available at https://www.ici.org/memo34806. For our joint comment letter on the proposal, see ICI Memorandum No. 35205, dated March 20, 2023, available at https://www.ici.org/memo35205.