relative value regs comment letter

VIA Electronic Filing April 28, 2005 CC:PA:LPD:PR (REG-152914-04) Courier’s Desk Internal Revenue Service 1111 Constitution Avenue, NW. Washington, DC 20044 Re: Relative Value Regulation Sir/Madam: The American Benefits Council (the “Council”) appreciates the opportunity to comment on the Revised Regulations Concerning Disclosure of Relative Values of Optional Forms of Benefit, which were issued as proposed regulations on January 27, 2005. The Council is a public policy organization representing principally Fortune 500 companies and other organizations that assist employers of all sizes in providing benefits to employees. Collectively, the Council’s members either sponsor directly or provide services to retirement and health plans that cover more than 100 million Americans. The Council respectfully requests that a public hearing be held on this matter and would like to testify at that hearing. The Council commends the Department of Treasury and Internal Revenue Service (collectively referred to as “Treasury”) for delaying the effective date of the relative value regulations with respect to certain distributions. However, in addition to delaying the effective date of the relative value regulations, the proposed regulations would expand the scope of an entirely different set of rules, the rules governing the valuation of certain distributions under Section 417(e). In particular, the proposed regulations provide that the ...