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Rules of Conduct for the New World of Deferred Compensation
Chang, Ruthenberg & Long 
[Guidance Overview] Feb. 11, 2009
Excerpt: The end of 2008 was also the end of the good faith reliance period for bringing deferred compensation plans into operational and documentary compliance with Code section 409A. It also ended the transitional guidance that permitted certain changes to existing plans without violating section 409A. This means that options are limited for correcting noncompliance, as well as for amending existing arrangements or designing new arrangements. This article offers some suggestions for operating under the new regime.
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