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The International Implications of §409A and its Impact on Multinational Companies
Faegre Drinker [Guidance Overview] Feb. 7, 2008 6 pages. Excerpt: Deferred compensation arrangements issued by foreign-owned operations or by US companies with operations abroad were not originally exempt from the application of §409A. However, under proposed and now final regulations issued by the IRS, there are exemptions that apply which are geared towards limiting the effect of §409A on non-resident aliens and US citizens or residents who participate in non-US plans. |
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