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IRS Provides Employees Opportunity to Cancel Non-Qualified Deferral Elections Through Self-Certification
Seyfarth
[Guidance Overview] Aug. 11, 2020 "Code Section 409A permits the cancellation of non-qualified plan deferral elections following a 401(k) plan hardship distribution.... CARES Act distributions may be based solely on self-certification by the participant. Effectively then, a participant could elect a $1 CARES Act distribution by self-certifying that COVID-19 adversely impacted the participant and in doing so, cancel potentially significant remaining non-qualified plan deferrals." |
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