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Insured Retirement Institute Comment Letter to IRS on Proposed Regs on Longevity Annuity Contracts (PDF)
Insured Retirement Institute [IRI] Link to more items from this source
[Opinion]
May 3, 2012
"First, it is [the Institute's] understanding that, under the regulation, the failure to comply with the 25% or $100,000 limits would void the entire contact as a QLAC. [The Institute suggests] that a system could be developed that would allow for a correction to a mistake in calculations. The amount that would be over the limits would be applied to the participant's required minimum distribution calculation. However, the remainder of the QLAC would remain intact and would still ensure longevity protection for the participant."

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