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Impermissibly Linked 409A Plans (PDF)
Aon Consulting Link to more items from this source
[Guidance Overview]
May 14, 2010
3 pages. Excerpt: In Notice 2010-6, the IRS gave plan sponsors ... a means to correct certain documentary failures in plans subject to 409A, often with reduced or completely eliminated tax consequences. In that notice, however, the means by which they addressed linked plans was troublesome. The primary concern is that the examples of failure to comply contained in Notice 2010-6 include some situations that practitioners believed to be compliant under the final regulations.

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