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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Published In: Labor & Employment Updates, Tax Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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