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IRS Proposes Updates to Sec. 409A Rules
Ropes & Gray LLP Link to more items from this source
[Guidance Overview]
June 28, 2016

"The proposal introduces a single rule, applicable for all purposes, that looks generally to when an event results in currently taxable income.... The proposed rules ... [allow] a payment at death to be paid at any time designated by the payor or payee up to and including December 31 of the calendar year following the calendar year in which death occurs.... A separate portion of the release adjusts 409A proposed regulations issued in late 2008 (but not yet finalized) that prescribe how to measure the income required to be taken into account in the case of noncompliance with 409A."

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