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Large IRAs and High-Income Retirement Savers Targeted by Amendment to Budget Reconciliation Bill

Last week, Richard Neal (D-Mass), chairman of the House Committee on Ways and Means, unveiled an amendment to help fund the $3.5 trillion budget reconciliation legislation that is currently under consideration in Congress. The Neal amendment would make dramatic changes to the rules governing retirement plans for certain high-income taxpayers by imposing new asset limitations and prohibitions. It would also require distributions and IRA contribution limitations for certain individuals with retirement savings over $10 million, require distributions of Roth balances in excess of $20 million and end the practice of so-called “back-door” Roth conversions. These changes aim to effectively prohibit mega IRAs, which were the subject of extensive press reports earlier this year following ProPublica’s revelation of multiple large IRAs, including Peter Thiel’s $5 billion mega-Roth IRA.

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Treasury, IRS Announce Relief for Securities Lenders


Time to Read: 1 minutes Practices: Tax

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Today, the U.S. Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") announced relief for securities lenders who potentially had been subject to taxable capital gains and disallowance of losses from lending their securities to Lehman Brothers and its affiliates, which could not return the securities due to bankruptcy. Last week, Ropes & Gray had requested guidance for these lenders from Treasury and the IRS, and we are pleased with today's announcement. To read our request for guidance, please click here; to read the announced guidance, please click here. If you have questions related to the new guidance, please contact Rom Watson or your usual Ropes & Gray advisor.

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