Ms. Carol Weiser
Deputy Benefits Tax Counsel
U.S. Department of the Treasury
1500 Pennsylvania Ave, NW
Washington, DC 20220

Mr. William Evans
Attorney-Advisor, Office of Benefits Tax Counsel
U.S. Department of the Treasury
1500 Pennsylvania Ave, NW
Washington, DC 20220 Washington, DC 20220

Mr. Stephen Tackney
Deputy Associate Chief Counsel
Employee Benefits
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Ms. Victoria Judson
Associate Chief Counsel
Tax Exempt and Government Entities
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Ms. Cynthia Van Bogaert
Associate Chief Counsel
Tax Exempt and Government Entities
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224

Re: Revenue Ruling 2018-17 Withholding and Reporting with Respect to Payments from IRAs to State Unclaimed Property Funds

Ladies and Gentlemen,

The Securities Industry and Financial Markets Association (“SIFMA”)1 and the Investment Company Institute (“ICI”)2 appreciate your willingness to meet with us to discuss Revenue Ruling 2018-17 (the “Ruling”), which will impose withholding and reporting requirements on our members, among  others, when they transfer a shareholder’s Individual Retirement Account (“IRA”) to a state, pursuant to that state’s unclaimed property law. Members of SIFMA and ICI are concerned about the impact and unintended consequences that this Ruling will have on savers, broker dealers, and investment companies (mutual funds). In anticipation of this meeting, we are submitting this letter to highlight some of these concerns.

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