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Section 409A -- IRS Issues Proposed Regulations Governing Deferred Compensation
Buchanan Ingersoll & Rooney PC 
[Guidance Overview] Nov. 7, 2005
"The Regulations and related supplementary explanation ... cover many of the key issues that were not addressed in IRS Notice 2005-1, 2005-2 I.R.B. 274 (the 'Notice'), including guidance concerning the timing and form of distributions, the definition of 'performance-based compensation,' the manner in which delayed payments can be made to 'key employees,' and compliance with the prohibition against accelerating distributions."
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