The U.S. Department of the Treasury and the IRS released long-awaited final regulations under Internal Revenue Code § 409A on Tuesday (April 10, 2007). Code § 409A was enacted as part of the American Jobs Creation Act of 2004 and it regulates a broad range of compensatory plans and arrangements that are lumped together under the heading of "non-qualified deferred compensation plans." Spanning some 398 pages, the final rule preserves much of the approach taken in prior guidance, but it also makes some important changes and enhancements. Key features of the new regulations are included in this Mintz Levin Client Alert.