Employee Benefits Advisory: IRS/Treasury Announce Voluntary Correction Program for Operational Code Section 409A Violations


In Notice 2007-100 (the “Notice”), the Internal Revenue Service and the U.S. Department of the Treasury announced a voluntary correction program for operational violations of Internal Revenue Code (the “Code”) § 409A. Entitled, “Transition Relief and Guidance on Corrections of Certain Failures of a Nonqualified Deferred Compensation Plan to Comply with § 409A(a) in Operation,” the Notice is a cautious, though important, first step. This client advisory explains the key features (and limits) of the Notice.

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