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Pension Rights Center Comment Letter to IRS on Notice 2021-40, Physical Presence Requirement for Spousal Consents (PDF)
Pension Rights CenterLink to more items from this source
Oct. 4, 2021

13 pages. The temporary waiver of the physical presence requirement ... is based solely on the social distancing restrictions necessitated by a national public health emergency.... [T]he burden to justify any permanent change rests on the industry and business groups that have been heavily lobbying Treasury-IRS to eliminate the physical presence requirement for spousal consents.... [T]he business community"s arguments do not hold up, and should not be credited to support any permanent weakening of spousal protections."

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