Guest pcalore Posted December 6, 2004 Posted December 6, 2004 Section 409A now requires that participants in bonus deferral ararngements make an election to defer their bonus at least six months prior to the end of the applicable performance period. Most commentators are expecting Treasury to provide an exception for 2004 bonus payments paid out in 2005 because 409A was enacted into law so late in the year. Has anyone heard anything more specific?
mbozek Posted December 6, 2004 Posted December 6, 2004 The IRS will issue guidelines on 409A by Dec 21, including effective date rules. mjb
Guest pcalore Posted December 6, 2004 Posted December 6, 2004 Yes, I am aware that guidance is expected by the 21st, but that is cutting the process close. I was wondering if anyone has heard Sweetnum or anyone else from Treasury opine on the topic. I attended one conference where the response was not very definitive, it was the "you will not be punished for not being clairvoyant" response.
Guest LeeNunn Posted December 6, 2004 Posted December 6, 2004 We expect transition regulations next week. Treasury has scheduled a Teleconference on Dec 16 to discuss the regulations. Go to the ABA web site or call 202 662 8640. The cost is $175.
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