Submitted Comments

In its efforts to be sure that government representatives have the benefit of private practitioners' experience and perspectives when they are preparing new legislation or other guidance, the Committee prepares and submits written comments on proposed legislation, proposed guidance and other matters. What follows is a list of comments submitted since July 1, 1998:

1. Comments on Section 409A Regarding Funding Issues
2. Comments on Section 409A Regarding its Impact on Business Transactions
3. Comments Regarding Distribution Restrictions of Section 409A of the Internal Revenue Code
4. Comments Concerning Definition of Nonqualified Deferred Compensation Focusing on Foreign Plan Issues
5. Comments Concerning Proposal on Incentive Stock Options Under IRC Sections 421, 422 and 424
6. Comments Concerning Revenue Ruling 2002-41, 2002-28 IRB 75 and Notice 2002-45, 2002-28 IRB 93
7. Comments Concerning Code Section 403(b) Regulations Project
8. Comments Concerning § 419A(f)(5) in Response to IRS Notice 2003-24
9. Comments Concerning IRS and Treasury Department Proposal on Waiver of Section 411(D)(6) Protection for Certain Features of Defined Benefit Plans
10. Comments Concerning Proposed Regulations under Code Section 419A(f)(6)
11. Comments Concerning Proposed Regulations Under Sections 401 and 411 of the Internal Revenue Code and ERISA Section 204 Regarding the Interaction of Age and Benefit Accruals in Retirement Plans
12. Comments Concerning Proposed Rulemaking and Other Guidance Regarding Golden Parachute Payments
13. Comments Concerning Proposed Regulations on Split-Dollar Life Insurance
14. Comments Concerning Proposed Regulations Under Section 4980F of the Code
15. Comments Regarding Proposed Treasury Regulation § 1.414(v)-1
16. Supplemental Comments Concerning IRS Notice 2001–10
17. Comments Concerning FSA 199926034: FICA Liability for ESPPs
18. Comments Concerning Cafeteria Plan Regulations Under Internal Revenue Code Section 125
19. Comments Concerning Proposed Regulation on Qualified Transportation Fringe Benefits under Internal Revenue Code Section 132(F)
20. Comments Concerning IRS Notice 2001–10
21. Comments With Respect to Prop. Treas. Reg. §§ 1.401(A)(4)-8(B)(1) and 9(B)(2)(V) Governing So-Called “New Comparability Plans”.
22. Comments on the Voluntary Fiduciary Correction Program.
23. Comments on the Worker Economic Opportunity Act (Pub. L. No. 106-202).
24. Comments Concerning  401(k) Design Based Safe Harbors.
25. Comments Concerning the Identification of Highly Compensated Employees Under IRC §414(q) Following a Merger or Other Acquisition.
26. Comments on the Worker Economic Opportunity Act (PUB. L. NO. 106-202).
27. Comments Regarding Proposed Treasury Regulations Under Section 411(d)(6).
28. Comments Concerning Bankruptcy-Related Pension Legislation.
29. Comments Concerning Cash Balance Plans.
30. Comments Regarding Excise Tax Relief for Pension Coverage of Household Employees.
31. Comments Concerning Disclosures to Participants Regarding Lump Sum Retirement Benefits.
32. COBRA Comments.
33. Comments Regarding Veteran's Rights under USERRA.
34. Comments Concerning COBRA Regulations under Internal Revenue Code §4980B.
35. Comments Concerning Age Discrimination Issues in Cash Balance Plans.
36. Comments Concerning Notice 98-1.
37. Comments Concerning the Internal Revenue Service Employee Plans Compliance Resolution System (Revenue Procedure 98-22).
38. Comments Concerning Nondiscrimination Standards for Government Plans.
39. Comments on Using New Technologies in Administering Retirement Plans.
40. Comments Concerning Private Sector Pensions and Social Security Reform.
41. Comments Concerning Department of Labor Proposed Regulations Under ERISA Section 401(c).
42. Comments Concerning Notice 97-45, Highly Compensated Employee Definition.

Developing Comments

The Committee is working on comments about a variety of diverse issues that are in the forefront of benefits developments. We need your involvement in these projects. What follows is a list of those imminent comments and the person who is coordinating the Committee's response.