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Sponsors and Participants Must Follow 409A True to Form (PDF)
Milliman and White & Case in Benefits Law Journal
July 8, 2020 11 pages. "[T]he rules with respect to changing [benefit commencement date (BCD)] and changing the form of payment ... share a common purpose: preventing a participant from having the type of excessive control over the timing of payment that Code Section 409A was enacted to eliminate while, at the same time, containing certain exceptions that provide participants with some degree of flexibility in certain circumstances. This column examines how NDCP sponsors can navigate these rules to ensure that their NDCP comply with Code Section 409A with respect to changes in form of payment elections." MORE >> |
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