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Notice with Plan Document Correction Procedures for 409A Goes Way Beyond Correction Procedures
Michael Melbinger via Winston & Strawn LLP 
[Guidance Overview] Jan. 18, 2010 "On January 5, 2010, the IRS issued Notice 2010-6, Relief and Guidance on Corrections of Certain Failures of a Nonqualified Deferred Compensation Plan to Comply with section 409A(a).... Importantly, the Notice does much more than just offer correction methods. It contains numerous examples of situations that the 409A final regulations do not clearly address-- and provides for significant penalties for many plan provisions that a normal person might view as a foot fault." MORE >> |
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