Nonqualified deferred compensation plans often include anti-assignment language prohibiting a plan participant from assigning benefits to anyone. Because top-hat plans are exempt from most aspects of ERISA including the...more
Last summer the Internal Revenue Service updated its Audit Techniques Guide (“ATG”) for nonqualified deferred compensation arrangements. While the ATG provides little instruction on how the IRS will review nonqualified...more
The Internal Revenue Service (IRS) recently updated its “Nonqualified Deferred Compensation Audit Techniques Guide.” The Guide provides a framework for the IRS to audit nonqualified deferred compensation (NQDC) plans. Since...more