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| IRS's New Section 409A Correction Program Miller Johnson  [Guidance Overview] Mar. 16, 2010 Excerpt: Notice 2010-6 provides a 'second chance' for employers to bring their deferred compensation arrangements in compliance with the Section 409A requirements. In our experience, some employers have 'discovered' deferred compensation arrangements that were not previously identified as being subject to Section 409A. Further, some Section 409A plans may still include provisions that do not satisfy the applicable requirements or may have not been operated in compliance with Section 409A. |
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