[9902]
May 5, 1998
TO: PENSION COMMITTEE No. 23-98
PENSION OPERATIONS ADVISORY COMMITTEE No. 15-98
AD HOC COMMITTEE ON ROTH IRA ISSUES
RE: INSTITUTE COMMENT LETTER TO TREASURY DEPARTMENT ON ROTH IRA
ISSUES
______________________________________________________________________________
The Institute intends to submit a comment letter on various Roth IRA issues to the Treasury
Department and the Internal Revenue Service. As you are aware, Treasury and the Service have not yet
issued comprehensive guidance on Roth IRA issues. Attached is a draft comment letter containing eight
Roth IRA issues and proposed responses. In general, the comment letter addresses Roth IRA issues that
do not relate to pending Technical Corrections legislation. However, issue number eight, “reporting
issues applicable to error correction transactions,” directly relates to Technical Corrections legislation.
The comment letter addresses the following issues: general reporting and recordkeeping
responsibilities; reporting obligations for conversion transactions; application of section 3405 to
conversion transactions; minimum distribution rules; application of 4 year income inclusion rule to
conversion transactions “straddling” 1998 and 1999; application of aging rules to conversion
transactions “straddling” 1998 and 1999; effect of death of accountholder on 5-year aging rules; and
reporting rules applicable to error correction transactions.
Please note that the comment letter refers to the error correction issue, but does not contain a
detailed description of the provision or a proposed response. A detailed description of the reporting
issues related to the proposed error correction provision in both the House and Senate Technical
Corrections legislation is contained in a separate memorandum.
Please review the comment letter to Treasury and the memorandum on reporting issues
applicable to the error correction provision and provide your comments to the undersigned by COB,
Thursday May 14, 1998. You may fax your comments to (202) 326-5841, email them to ricard@ici.org
or call me at (202) 218-3563. Thank you for your attention to this matter.
Kathryn A. Ricard
Assistant Counsel
Attachments