Client Alerts

Final regulations have been issued under Section 409A

Chris Fenelon, Jerry Martin, Lee McMurtry and Lisa Young
April 24, 2007

On April 10, 2007, final regulations under Section 409A of the Internal Revenue Code were issued.[1]  Taxpayers have until December 31, 2007, to make any necessary amendments to covered nonqualified deferred compensation plans or arrangements (discussed below) to comply with the requirements of the final regulations.  The IRS has stated that this deadline will not be extended.


[1]       In addition, at the same time that the final regulations under Section 409A were released, Notice 2007-34 was issued.  The notice addresses how the final regulations impact split-dollar life insurance arrangements.

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