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IRS Embarks on 409A Audits: Staying in Shallow Waters?
Winston & Strawn LLP Link to more items from this source
May 13, 2014

"[It] appears the initiative is targeted primarily at traditional nonqualified deferred compensation plans, or 'top hat' plans ... If so, the scope of these audits would be relatively comfortable for both the Service and the employers because Section 409A, to the extent it is ever straightforward, applies most understandably and objectively to traditional top hat plans."

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