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SERP Shifts and IRC § 409A
Deloitte 
Oct. 12, 2006
Excerpt: In recent years, many companies have transferred executives' retirement benefits from nonqualified to qualified plans, using a technique commonly known as a 'SERP shift'.... With the enactment of IRC § 409A ... these arrangements need to be scrutinized to make sure that they comply with the new law. Fortunately, the IRS's proposed regulations under IRC § 409A offer broad leeway for the continued use of SERP shifts.
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