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IRS Document Correction Program

Feb 19, 2010 - Alerts by

The IRS has recently stepped up efforts to enforce Section 409A of the Internal Revenue Code (the “Code”). This is bad news for any companies that missed the January 1, 2009, IRS deadline to amend nonqualified deferred compensation plans and arrangements. It is even worse news for participants in those plans and arrangements, because the full force of any Code § 409A violations – including a 20% penalty tax – can hit participants like a ton of bricks.

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