17 pages. "The final regulations should not be effective until, at the earliest, calendar years beginning at least 9 months after the final regulations are released.... The Service should not modify the rules for 403(b) plans, or if it does, only through a separate regulatory proposal. The final regulations should modify the Service's interpretation of the 10-year rule, or if not, provide relief for prior years. The Service should reconsider whether the Proposal's rules for withholding on distributions to non-spouse beneficiaries correctly reflect the Code.... The Proposal's rule regarding a 'hypothetical' RMD should be removed. The final regulations should retain age 21 as the age of majority."

MORE >>