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2021 Year-End Tax Issues for Non-Qualified Plans (PDF)
Ivins, Phillips & Barker Link to more items from this source
[Guidance Overview]
Nov. 24, 2021

"Payments due in 2021 and paid 'late' but prior to 2022 often are not 409A failures at all. Other same year issues can be corrected with minimal consequence. 2020 failures to defer or timely pay can be corrected with minimal consequence in 2021 as long as the participants were not 'insiders' ... 2019 failures to defer or timely pay (or 2020 failures involving insiders) can be corrected with reduced consequences in 2021."

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