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IRS Q&A Compendium for Actuaries No Longer Produced

The “Gray Book,” a compendium of questions actuaries pose to the IRS and the answers to them, will no longer be produced. The Conference of Consulting Actuaries (CCA), which had produced the book with the American Academy of Actuaries, recently made the announcement.

The CCA said that it has taken this step in part because the IRS and Treasury Department have reallocated resources and shifted their priorities. In addition, the government is concerned over the reliance placed on the answers the IRS was providing in the Gray Book.

The move reflects a constriction in the ways in which the IRS provides informal information that is not in the form of guidance, and government concern over the extent to which recipients may treat it as formal guidance. The IRS Employee Plans Office had announced on July 31, 2015, that effective Oct. 1, it would no longer answer technical questions by email, nor would it accept forwarded messages from IRS Customer Account Services that had been sent to its personnel by email. Among the reasons it cited was that the Employee Plans Office lacked the resources to do research and also provide answers for legal topics. Commissioner of the IRS Tax Exempt and Government Entities Division Sunita Lough reiterated at an Oct. 20 update on federal agency activity at the 2015 ASPPA Annual Conference that the IRS will not backtrack on that decision.