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Premium Interest Tax for 409A Failures (PDF)
Aon Hewitt in Journal of Deferred Compensation 
[Guidance Overview] Mar. 6, 2018
17 pages. "IRC Section 409A and Proposed Treasury Regulations established premium interest tax as an additional income tax on Section 409A failures. The purpose of the tax is to retroactively disqualify deferrals from having received tax-deferred status without causing an extreme administrative burden on plan sponsors or participants.... This article will describe a comprehensive list of steps used to calculate premium interest tax as well as explore common issues with each step."
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