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IRS Chief Counsel Memo Advises that Salary Advances May Violate IRC Section 409A
Deloitte Link to more items from this source
[Guidance Overview]
Sept. 9, 2009
Excerpt: The IRS informally advised that an employer's salary advance program would violate IRC § 409A because it allowed the salary advances to be offset against the recipient's nonqualified deferred compensation benefit at termination of employment. Chief Counsel Advice Memorandum 200935029 (Released 8/28/2009).

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