5 pages. "[The preamble to the proposed regulations states that,] when one portion of a retirement benefit distribution subject to the section 417(e) factors is a 'decreasing' benefit, both portions of the distribution are subject to the minimum present value requirements of section 417(e)(3). The Council believes that the current regulation does not clearly require that, and can be reasonably interpreted to reach the opposite result. Due to this uncertainty, the Council believes that the clarification of the rules, as provided by the proposed regulations, should apply prospectively, and that Treasury and the Service should clearly state that no inference should be drawn regarding the law prior to the effective date of the final regulation."  MORE >>