退休保障:改进指导可以帮助账户所有者了解投资非常规资产的风险

Charles A. Jeszeck, Christopher Falcone, D. Lehrer, E. Gruenwald, Jay McTigue, Jessica Moscovitch, John P. McMurray, MaryLynn Sergent, Tom Moscovitch
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引用次数: 0

摘要

迄今为止,联邦政府的数据收集工作几乎没有收集到有关持有非常规资产(如房地产、贵金属、私募股权和虚拟货币)的退休账户的信息,这使得此类账户的普遍程度不得而知。在2015纳税年度,美国国税局(IRS)开始要求个人退休账户(IRA)的托管人或受托人(包括银行或其他获准持有账户资产的机构)向国税局报告其客户账户中非常规资产的选定信息。截至2016年11月,IRS计划在2017年开始编制新的IRA资产数据,但尚未指定新的IRA资产数据何时可用于分析。在政府问责局认定的26家托管机构中,有17家允许退休账户持有非常规资产,并参与了政府问责局的数据收集工作。截至2015年年底,这些托管机构托管了近50万个此类账户。个人退休账户占报告账户和资产的绝大部分。IRA所有者投资非常规资产的决定可以大大扩展他们的角色和责任。政府问责局对行业文件的审查发现,希望通过个人退休账户投资非常规资产的个人通常同意负责监督账户投资的选择、管理和监控,并承担影响其账户的大多数决策的后果。例如,此类账户的所有者承担受托人的角色,这使他们承担更大的责任,监督账户投资的选择、管理和监控,并承担影响其账户的大多数决策的后果。目前美国国税局的指导几乎没有提供任何信息来帮助IRA所有者了解他们扩大的责任和与投资非常规资产相关的潜在挑战。IRS针对这些IRA所有者的针对性指导可以帮助他们应对与某些类型的非常规资产相关的潜在合规挑战。例如,GAO发现一些IRA所有者可能会在以下方面遇到挑战:•监控持续的联邦纳税义务:IRA所有者并不总是意识到需要监控其账户中某些非常规资产的总收入,以应对持续的联邦纳税义务。例如,投资于活跃企业或债务融资房产的IRA所有者需要监控他们的账户,以了解必须从IRA支付的持续纳税义务。如果不这样做,可能会导致支付不足的罚款。•获得非公开交易资产的年度公平市场估值:投资于难以估值的非常规资产的IRA所有者可能面临向其托管人提供最新公平市场价值信息以满足IRS年度报告要求的挑战。未能及时提供最新的公平市场价值可能导致托管人过早地以公平市场价值将账户资产分配给所有者。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
Retirement Security: Improved Guidance Could Help Account Owners Understand the Risks of Investing in Unconventional Assets
Federal data collection efforts to date have captured little information on retirement accounts holding unconventional assets — such as real estate, precious metals, private equity, and virtual currency — making the prevalence of such accounts unknown. In tax year 2015, the Internal Revenue Service (IRS) began requiring that custodians or trustees of individual retirement accounts (IRA) — including banks or other institutions approved to hold account assets — report selected information on unconventional assets in their clients' accounts to IRS. As of November 2016, IRS plans to begin compiling the new IRA asset data in 2017, but has not specified when the new IRA asset data will be available for analysis. Seventeen of the 26 custodians, who GAO identified as allowing retirement accounts with unconventional assets and who participated in GAO's data collection effort, reported having nearly half a million of these accounts in their custody at the end of calendar year 2015. IRAs made up the vast majority of accounts and assets reported.An IRA owner's decision to invest in unconventional assets can expand their role and responsibilities substantially. GAO's review of industry documents found that individuals wanting to invest in unconventional assets through their IRA generally agree to be responsible for overseeing the selection, management, and monitoring of account investments and shoulder the consequences of most decisions affecting their accounts. For example, owners of such accounts assume a fiduciary role, which makes them assume greater responsibility for overseeing the selection, management, and monitoring of account investments, and shoulder the consequences of most decisions affecting their accounts.Current IRS guidance provides little information to help IRA owners understand their expanded responsibilities and potential challenges associated with investing in unconventional assets. Targeted IRS guidance for these IRA owners may help them navigate the potential compliance challenges associated with certain types of unconventional assets. For example, GAO found that some IRA owners can experience challenges in the following areas:• Monitoring for ongoing federal tax liability: IRA owners are not always aware of the need to monitor the gross income from certain unconventional assets in their accounts for ongoing federal tax liability. For example, IRA owners who invest in active businesses or debt-financed properties need to monitor their accounts for ongoing tax liability that must be paid from the IRA. Failure to do so can result in underpayment penalties.• Obtaining annual fair market valuations for nonpublicly traded assets: IRA owners investing in hard-to-value unconventional assets can face challenges meeting their responsibilities to provide updated fair market value information to their custodian to meet IRS's annual reporting requirement. Failure to provide an updated fair market value in a timely manner can result in a custodian prematurely distributing account assets to the owner at a fair market value that is.
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