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The Intersection of Sections 457(f) and 409A: Is Guidance Really Imminent? (PDF)
Groom Law Group Link to more items from this source
Jan. 7, 2016
"At this point, it is not yet clear what the nature of any transition relief under the proposed regulations will be. While informally the Service has indicated there will be some such relief, it is not anticipated that it will either provide a general grandfather for existing arrangements or cover some of the more aggressive designs under Code section 457 that have been known to be used in the past."

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