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Navigating the Code § 409A Transitional Rules
Mintz Levin Cohn Ferris Glovsky and Popeo P.C. 
Oct. 27, 2005
Excerpt: In Notice 2005-1, the IRS and Treasury first announced transition rules governing the treatment of deferred compensation arrangements under the American Jobs Creation Act of 2004, which enacted new Code § 409A. A recently proposed Treasury regulation furnished additional guidance expanding some but not all of the Notice 2005-1 transition rules. This Advisory explains the Code § 409A transition rules as embodied in both Notice 2005-1 and the proposed rule.
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