[9985]
June 3, 1998
TO: PENSION COMMITTEE No. 34-98
PENSION OPERATIONS ADVISORY COMMITTEE No. 20-98
AD HOC ROTH IRA WORKING GROUP
RE: INSTITUTE SEEKS ROTH IRA GUIDANCE FROM THE TREASURY
DEPARTMENT
______________________________________________________________________________
The Investment Company Institute has submitted a letter, dated June 3, 1998, to the Treasury
Department seeking guidance on unresolved issues relating to the Roth IRA. With one exception (issue
number seven, below), the letter requests guidance on issues not addressed by pending technical
corrections legislation.
Specifically, the letter, which was developed with the assistance of Institute members, requests
clarification with respect to the following Roth IRA issues: (1) reporting and recordkeeping
responsibilities of Roth IRA trustees and custodians; (2) the application of section 3405 to conversion
transactions; (3) the application of the 4-year income inclusion rule to conversion transactions
“straddling” 1998 and 1999; (4) the application of aging rules to conversion transactions “straddling”
1998 and 1999; (5) the effect of death of accountholder on aging rules; (6) the application of minimum
distribution rules to taxpayers who convert a traditional IRA to a Roth IRA; and (7) reporting rules
applicable to Roth IRA error correction transactions.
A copy of the letter is attached.
Kathryn A. Ricard
Assistant Counsel
Attachment