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| IRS Releases Nonqualified Deferred Compensation Audit Techniques Guide Winston & Strawn LLP  June 23, 2015 "[D]espite the first update since 2005, the new Audit Technique Guide (ATG) leaves the impression that 409A is only a minor concern for the IRS auditors of nonqualified deferred compensation plans. However, maybe that is the message IRS is trying to send to us, to wit, in your obsession with 409A, don't ignore all of the other rules that apply to nonqualified deferred compensation plans." |
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