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IRS's Initial Guidance Governing Non-Qualified Deferred Compensation under Code §409A (PDF) Mintz Levin Cohn Ferris Glovsky and Popeo P.C. ![]() Jan. 6, 2005 5 pages. Excerpt: Taxpayers are entitled to rely on Notice 2005-1. Any future guidance that is less favorable will only be applied prospectively. Where the guidance is silent on a particular item, taxpayers are permitted to apply a 'good faith' interpretation of the rules taking into account the statute, its purpose, and its legislative history. |
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