July 1, 1992
TO: PENSION COMMITTEE NO. 22-92
RE: INSTITUTE SUBMISSION CONCERING REGULATORY BURDEN REDUCTION
INITIATIVE
__________________________________________________________
Attached is a copy of the Institute’s submission to the IRS
in response to the regulatory burden reduction initiative
announced in Notice 92-12. (See Institute Memorandum to Pension
Committee No. 18-92, dated May 5, 1992.)
The submission supports the proposed closing of the
regulations project under section 6047(d) of the Code, which
would have required the payor of a qualified plan distribution
(or the plan administrator) to calculate the taxable amount and
to report it on the appropriate information return. In addition,
the Institute submission recommends that the existing retirement
plan reporting requirements be modified to eliminate the coding
of distributions as to their status under section 72(t). The
submission also reiterates the Institute’s recommendations
concerning the definition of "qualified replacement property"
under section 1042 and joint and survivor annuity requirements
under section 417. (See Institute Memorandum to Pension
Committee No. 41-91, dated December 27, 1991.)
We will keep you informed of further developments.
Kathy D. Ireland
Associate Counsel -Pension
Attachment