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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
[Opinion]
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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