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Guest newtobenefits

409A "Correction" Now that we are outside of Correction Notice Transition Period

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Guest newtobenefits

Facts: payment should have been made in 2007. It was not and the error was just discovered. Payment will be made in 2010. Since we are after 12/31/09, we assume there is no relief under the correction notice's transition period. So then, this is a full blown error w/ reporting and income inclusion.

A few questions we cant seem to find direct guidance on:

1- Should reporting be made on a corrected 2007 W2 or 2010 W2?

2- Should the amount of the account in 2007 be paid or the amount as it stands today (which has increased)?

Thanks.

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I vote for amending the 2007 W-2 and no plan earnings credited since that date, with the hope final regs clarify.

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