Revenue Ruling 2018-17 Withholding and Reporting

Published on:
September 10, 2018
Submitted to:
IRA
Submitted by:
SIFMA and ICI

Summary

SIFMA and ICI provided comments regarding the new Revenue Ruling 2018-17, which will impose withholding and reporting requirements on members with respect to payments from IRAs to state unclaimed property funds. Our concerns with things such as our authority to liquidate assets to satisfy the withholding obligation, reporting concerns, operational difficulties, client impact, and the upcoming implementation date.

See also:

Rev. Rul. 2018-17 Withholding and Reporting With Respect to Payments From IRAs to State Unclaimed Property Funds

Excerpt

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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