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IRS Issues Proposed Revisions to Section 409A Regs
Alvarez and Marsal Link to more items from this source
[Guidance Overview]
Aug. 11, 2016

"The proposed regulations clarify that the provisions relating to payments made upon death of a service provider apply equally to beneficiaries of a service provider. In addition, 409A will also allow payments to beneficiaries upon their disability or in the event of an unforeseeable emergency.... The proposed regulations clarify that ... if a service recipient maintains multiple plans of the same type that cover different unique employee populations, all such plans must be terminated if the service provider wishes to use the bankruptcy rule to terminate one or more such plans -- even though no employee participates in more than one such plan of the service provider."

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