Section 801(a) of the Tax Extenders and Alternative Minimum Tax Relief Act of 20081 added to the Internal Revenue Code (the “Code”) new Section 457A. Code § 457A changes the tax rules that apply to deferred compensation arrangements maintained by certain foreign corporations and domestic and foreign partnerships. On January 9, 2009, the IRS issued Notice 2009-8, which provides interim rules implementing Code § 457A and invites comments on certain aspects of the new law. This client advisory explains the key features of Notice 2009-8.
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