Institute Files Comment Letter on Roth IRA Guidance

Washington, DC, December 3, 1998 - The Institute has filed a comment letter on proposed regulations regarding Roth IRA issues and Internal Revenue Service Notices 98-49 and 98-50. With respect to Notice 98-49, the Institute commented on the following issues: recharacterization transaction reporting requirements, Internal Revenue Service reporting alternatives for recharacterization transactions, Service-approved Roth IRA documents, and reporting conversion transactions involving withholding. With respect to Notice 98-50, the Institute requested guidance on the issue of partial recharacterizations. Finally, with respect to the proposed regulations, the Institute requested clarification on the following issues: recharacterization by beneficiaries, withholding rules applicable to recharacterizations, minimum required distributions and the surviving spouse, decedents who die during the 4-year spread for 1998 conversions, and conversions of SIMPLE IRAs.