n-18-90.pdf

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Extension of Transition Relief Under Rev. Rul. 2018-17 on Withholding and Reporting
With Respect to Payments From IRAs to State Unclaimed Property Funds

Notice 2018-90

I. PURPOSE
The purpose of this notice is to extend the withholding and reporting transition relief
described in Rev. Rul. 2018-17, 2018-25 IRB 753, that applies with respect to payments
made before the earlier of January 1, 2019, or the date it becomes reasonably
practicable to comply with those requirements. Relief is extended to payments made
before the earlier of January 1, 2020, or the date it becomes reasonably practicable to
comply with the withholding and reporting requirements described in Rev. Rul. 2018-
17.
II. BACKGROUND
Rev. Rul. 2018-17 addressed federal income tax withholding under § 3405 of the
Internal Revenue Code and reporting under § 408(i) relating to payment of an
individual’s interest in an IRA to a State unclaimed property fund, as required by State
law. Under the facts presented in Rev. Rul. 2018-17, payments from an IRA to a State
unclaimed property fund are subject to federal income tax withholding and reporting.

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However, Rev. Rul. 2018-17 included the following transition relief: “A person will
not be treated as failing to comply with the withholding and reporting requirements
described in this revenue ruling with respect to payments made before the earlier of
January 1, 2019, or the date it becomes reasonably practicable for the person to comply
with those requirements.”
The Department of the Treasury and the Internal Revenue Service have received a
number of requests for an extension of the transition relief in Rev. Rul. 2018-17.
III. EXTENSION OF TRANSITION RELIEF UNDER REV. RUL. 2018-17
The transition relief in Rev. Rul. 2018-17 is extended so that a person will not be
treated as failing to comply with the withholding and reporting requirements described in
Rev. Rul. 2018-17 with respect to payments made before the earlier of January 1, 2020,
or the date it becomes reasonably practicable for the person to comply with those
requirements.
IV. EFFECT ON OTHER DOCUMENTS
Rev. Rul. 2018-17 is modified.
V. DRAFTING INFORMATION
The principal author of this notice is Cynthia Van Bogaert of the Office of Associate
Chief Counsel (Tax Exempt and Government Entities). Ms. Van Bogaert may be
reached at (202) 317-4102 (not a toll-free number).