LTPT

Anyone have a "contact" at the IRS to know, first, IF they are planning to release any additional guidance on this subject, and if so, WHEN might it be expected?

IRS Regulatory agenda has proposed regs scheduled for December, 2023.

Which, of course, doesn't preclude the possibility of additional (sub-regulatory) guidance between now and then.

Thanks Lois.

I'm not seeing anything mentioned in the regulatory agenda regarding Secure 2.0 section 603 for Roth catch-up?  

41 minutes ago, DMcGovern said:

I'm not seeing anything mentioned in the regulatory agenda regarding Secure 2.0 section 603 for Roth catch-up?  

Could they be waiting for Congressional action via technical corrections?  The problem is in large part statutory at this point, no?

"Could they be waiting for Congressional action via technical corrections?  The problem is in large part statutory at this point, no?"

I did see where it was part of the open letter to Secretary of the Treasury Janet Yellen and IRS Commissioner Daniel Werfel that addressed the technical correction needed to allow for catch-up contributions.  I suppose they could be waiting on this before addressing other issues with this provision.

The notice is to publish the NPRM on "12/00/2023" for public comment starting in December.  So kinda sorta the IRS is going to put out there their best guess on what to do and it will be a while before anything becomes hard guidance.  That is going to leave us all to gamble on an interpretation.

The drafting and reviewing attorneys' contact information is available on the reginfo.gov if anyone wants to get a head start on comments:

https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202304&RIN=1545-BQ70