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Be Ever Vigilant Regarding 409A and Include 409A Interpretive Provisions!
The Bureau of National Affairs, Inc. 
[Guidance Overview] Feb. 5, 2012
Although the IRS has issued correction programs for both operational (IRS Notice 2008-113) and document (IRS Notice 2010-6) failures, not all 409A issues are included in such correction programs. Even corrections within the programs can cause employees to incur additional tax, tax reporting complications and different-than-desired payment timing so ongoing 409A compliance is important.
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