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2000
Manage | s y s c o m : g m

On December 11, 2000, ASPPA provided the Internal Revenue Service with additional comments on IRS Notice 99-44, Section 415 Limitations on Benefit and Contributions Under Qualified Plans. [Comment]

On October 31, 2000, ASPPA wrote a letter to the Department of Labor requesting a reduction in the penalties associated with their DFVC program. [Comment]

On October 29, 2000, ASPPA wrote the Internal Revenue Service commending them on the publication of the Proposed and Final Regulations under 72(p) of the Internal Revenue Code and providing suggestions for further improvements. [Comment]

On October 27, 2000, ASPPA wrote a letter to the Department of Labor suggesting the Pension and Welfare Benefits Administration publicize the availability of ERISA Procedure 76-1 for issues which affect tax-sheltered annuity arrangements described in Section 403(b) of the Internal Revenue Code. [Comment]

On September 11, 2000, ASPPA wrote to the Internal Revenue Service commending the Service on its recent issuance of guidance concerning the Employee Plans Compliance Resolution System, and providing suggestions on further improvements. [Comment]

On May 18, 2000, ASPPA wrote Ms. Carol R. Gold, IRS, a letter commenting on Notice 2000-3. [Comment]

On May 18, 2000, ASPPA wrote Virginia C. Smith, Director of Enforcement, VFC Program, offering comments in regard to the Department of Labor's Notice of a Voluntary Fiduciary Correction Program (VFC Program). [Comment]

On May 18, 2000, ASPPA wrote Ms. Carol R. Gold, IRS, regarding the issuance of Revenue Procedure 99-45 and concerns that our earlier comments on Revenue Procedures 95-51 and 98-10 may not have been adequately considered. ASPPA is also concerned with how IRS field actuaries seem to have been interpreting Section 4.02 of Revenue Procedure 95-51 as required changes rather than optional changes. [Comment]

On May 2, 2000, ASPPA wrote The Honorable Orrin Hatch, Chairman of the Senate Committee on the Judiciary, expressing our strong opposition to adding any provision to the Bankruptcy Reform Act of 2000 (H.R. 833) that would cap the amount of retirement plan assets entitled to protection from creditors in bankruptcy.[Comment]

On April 15th, ASPPA wrote Mr. John J. Canary, Chief, Division of Coverage, Reporting and Disclosure, DOL, regarding the need for an additional extension for filing Form 5500 series forms, and on guidance needed for filing Short Plan Year Return/Reports (5500). [Comment]

On March 28, 2000, ASPPA wrote to the Internal Revenue Service regarding the issuance of guidance on the section 457(e)(11) exception for bona fide severance pay plans. [Comment]

On February 2, 2000, ASPPA wrote to the Department of Labor regarding the proposed rule that would amend the regulations governing the circumstances under which small pension plans are exempt from the requirements to engage an independent qualified public accountant. [Comment]