IRS Minimum Distribution Regulation Delayed

[Guest Calimayhew]

Does anyone have any more information about this?

www.ncpers.org/nm/publish/news_67.html

Of course, the IRS website is less than helpful.

[MGB]

Only that IRS officials have said this a few times in recent weeks. I was one of the people testifying on 10/9 in addition to NCPERS and, yes, they were taken aback by what was said. So, they've decided to go back to the drawing boards. They again said it this week at the CCA meeting in Florida. Nothing official has been released extending the effective date yet.

[MGB]

Also note that this is only in conjunction with defined benefit plans or annuities purchased from insurance companies. The DC and IRA rules are final and would not be delayed or changed.

[david rigby]

Any link to other testimony?

[MGB]

I did not post my testimony, but the following is my original written comments that are a little more detailed (only 10 minutes per person in testimony):

http://www.milliman.com/files/IRS_reg1.401.pdf

I did do some specific calculations to use in the testimony that were only alluded to in the above through verbal discussion. These were with respect to the value of various types of death benefits (J&S, account balance, etc.) under the new mortality table and how they compare between DB and DC rules and whether they violate long-standing guidance on incidental rules.

The following is testimony from the American Benefits Council which I also had a hand in (and would have presented if we weren't providing our own):

http://www.appwp.org/documents/abc401a9tes...st1009final.pdf

Their written comments are at:

http://www.appwp.org/documents/401a9rev702.pdf

The following is the written version of the Public Plans Task Force of the Pension Committee of the Academy of Actuaries:

http://www.actuary.org/pdf/pension/irs_16july02.pdf

Larry Johannsen split his 10 minutes between the above Academy testimony and representing the New York system (he is their chief internal actuary).

[Guest jody303]

Have there been any further developments, e.g., official IRS announcement on this?

[MGB]

Not yet...still waiting.