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IRS Extends Transition Relief for New Escheated IRA Tax Withholding, Reporting Rules
Morgan Lewis Link to more items from this source
[Guidance Overview]
Dec. 6, 2018

"[T]he extended transition relief applies to payments made before the earlier of January 1, 2020, or the date it becomes reasonably practicable to comply with the new rules.... [Rev. Rul. 2018-17] is silent as to whether the IRA owner may roll the escheated IRA over to an eligible IRA and, if the rollover is permitted, when the 60-day period to make the rollover begins.... The Revenue Ruling is also silent as to whether an IRA owner who is under age 59-1/2 at the time of an escheatment (in those states that escheat before the IRA owner reaches age 70-1/2) would be liable for the 10% penalty tax for early IRA distributions.... [It also] does not address the tax withholding and reporting requirements for a SEP, SIMPLE, or Roth IRA."

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