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The Impact of IRS Final 409A Regs on U.S. Participants in Foreign Deferred Compensation Plans
Deloitte 
June 5, 2007
Excerpt: In a globalizing economy, many non-U.S. companies maintain deferred compensation arrangements in which U.S. citizens or residents participate, while many Americans participate in their foreign employers' plans. Section 409A is thus more than domestic tax law.... Some potential problems are ameliorated by the final regulations, but many complications and traps for the unwary remain.
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