June 7, 2005 VIA EDGAR Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 ATTN: Mr. Mark Cowan Senior Counsel Office of Insurance Products Division of Investment Management RE: IDS Life of New York Account 8 ("Registrant") CIK: 0000817132 SEC File No.: 333-44644 Withdrawal of 485APOS Filing Post Effective Amendment No. 9 filed on behalf of the Registrant on Form N-6 on or about November 18, 2004 ("Amendment No. 9") Accession Number: 0000820027-04-000966 Withdrawal of 485BXT Filing Post Effective Amendment No. 11 filed on behalf of the Registrant on Form N-6 on or about January 14, 2005 Accession Number: 0000820027-05-000015 Withdrawal of 485BXT Filing Post Effective Amendment No. 12 filed on behalf of the Registrant on Form N-6 on or about February 16, 2005 Accession Number: 0000820027-05-000132 Dear Mr. Cowan: Pursuant to Rule 477(a) of the Securities Act of 1933, Registrant hereby respectfully requests withdrawal of the filings captioned above. Amendment No. 9 captioned above contained supplements describing certain product enhancements. Registrant filed the two 485BXT Filings captioned above to extend the effective date of Amendment No. 9 pending approval of the product enhancements described in the supplements by the New York Superintendent of Insurance. Because the New York Superintendent of Insurance has not yet approved the product enhancements, Registrant respectfully requests withdrawal of the filings captioned above. Registrant represents that no securities were sold in connection with the supplements contained in Amendment No. 9. In addition, Registrant has subsequently filed a 485BPOS Filing (Post Effective Amendment No. 13 filed on behalf of the Registrant on Form N-6 on or about April 28, 2005) that supercedes the filings captioned above. If you have any questions, please contact me at 612-671-3678. Sincerely, /s/ Mary Ellyn Minenko - ----------------------- Mary Ellyn Minenko Assistant General Counsel and Assistant Secretary IDS Life Insurance Company of New York