IRC Section 412 comment letter (Aug. 13, 2002)

August 13, 2002 William Sweetnam, Esq. Benefits Tax Counsel Office of the Benefits Tax Counsel U.S. Department of the Treasury Room 1000 1500 Pennsylvania Avenue, N.W. Washington, D.C. 20020 Dear Bill: The American Academy of Actuaries’ Pension Committee recently formed a task force to examine regulatory issues under section 412 of the Internal Revenue Code (IRC). As chair of the Pension Committee, I am writing to share with you the recommendations of that task force. Specifically, the task force examined areas under section 412 that either lacked regulatory guidance, or for which existing guidance needed clarification. The task force then put together a number of proposals intended to provide clarity to actuaries about several of these areas. Those proposals are summarized in the attached document. We would be delighted to meet in person to discuss these recommendations. In the meantime, please do not hesitate to contact Todd Tuten, the Academy’s Director of Public Policy, if you have any questions or comments. He can be reached by telephone at (202) 223-8196, or by email at tuten@actuary.org. Thank you in advance for your consideration of these recommendations. Sincerely, Donald J. Segal Chair, Pension Committee American Academy of Actuaries cc: Paul Shultz James Holland 1100 Seventeenth Street NW Seventh Floor Washington, DC 20036 Telephone 202 223 8196 Facsimile 202 872 1948 ...