Memo #
3803

IRS ANNOUNCES DEADLINE FOR AMENDMENT OF IRAS

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May 27, 1992 TO: PENSION MEMBERS NO. 10-92 RE: IRS ANNOUNCES DEADLINE FOR AMENDMENT OF IRAs __________________________________________________________ Attached is a copy of Revenue Procedure 92-38, which provides notice that individual retirement arrangement trusts and custodial account agreements must be amended to provide for the minimum required distribution rules in section 408(a)(6) of the Code. The revenue procedure does not apply to sponsors of prototype IRAs that received opinion letters dated after January 31, 1990. An IRA prototype sponsor may continue reliance on a previously issued opinion letter either by adopting model language set forth in the revenue procedure by May 18, 1993, or by submitting individually drafted amendments to the IRS by that date. IRAs that were established by executing Form 5305 or 5305A must continue to operate in compliance with section 408(a)(6) until the IRS issues revisions to these forms. We will keep you informed of further developments. Kathy D. Ireland Associate Counsel - Pension Attachment

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