12/22/2006: Overview of Guidance Issued on Reporting and Wage Withholding under Code § 409A (Mintz Levin Cohn Ferris Glovsky and Popeo P.C.)

Excerpt: While this guidance provides some welcome relief (e.g., the requirement that 2005 deferrals not be reported is extended to 2006), there is a premium placed on compliance for other purposes (e.g., the waiver of certain late filing and payment penalties). This client advisory explains the key features of this recent guidance and the steps that plan sponsors need to take in response.