Section 409A Compliance Deadline Fast Approaching

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The December 31, 2008, deadline for compliance with Section 409A of the Internal Revenue Code ("Section 409A") is quickly approaching, and employers should thoroughly review all "nonqualified deferred compensation arrangements" (as broadly defined by the Internal Revenue Service) to ensure documentary compliance by year-end. In addition, any necessary amendments or restatements to such arrangements must be adopted no later than December 31, 2008.

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