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Targeted IRS Examinations of Section 409A Compliance
Bloomberg BNA Link to more items from this source
July 9, 2014
"Section 409A [Information Document Requests] have been extremely detailed, effectively requiring the employer to take specific legal positions on Section 409A compliance to respond. In most cases the examination will involve interviews of employees involved in Section 409A compliance. These interviews should be approached strategically. Careful preparation of the witnesses based on experience with IRS interview procedures and content can be extremely beneficial."

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