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Senior Counsel – Investment Solutions Great Gray Trust Company
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Retirement Relationship Manager MAP Retirement
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Almost 20 Years of Section 409A: Is Your Documentation Still in Sync?
Seyfarth
[Guidance Overview] Feb. 9, 2026 "As the 20‑year mark approaches, now is the perfect moment for a quick compliance check. Over time, plan administration often drifts from what the written document actually says. And with Code Section 409A's unforgiving rules, even small mismatches can trigger significant tax implications for the participant, including immediate income inclusion, a 20% penalty tax on the amount involved, and additional penalties and interest. Worse yet, Code Section 409A often limits an employer's ability to fix problems simply by amending the written plan document." MORE >> |
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