SIFMA provides comments to the Internal Revenue Service (IRS) on Notice of Proposed Rulemaking under Internal Revenue Code (Code) Section 529 Accounts for qualified tuition programs.  SIFMA shares its experience and recommendations on how to coordinating the effects that  Section 529 has on both the income and the estate and gift tax provisions of the Code and the favorable treatment that section 529 plans enjoy. SIFMA agrees with a number of the proposals, but believes that some of the proposed rulemaking provisions might include account transactions that are not abusive and that use the tax benefits as they were intended.