October 26, 2007
Employee Benefits and Executive Compensation Update
SECTION 409A AMENDMENT AND TRANSITION DATES EXTENDED TO DECEMBER 31, 2008
The Internal Revenue Service had previously extended to December 31, 2008 the date for nonqualified deferred compensation plans and arrangements to be amended to comply with most of the provisions of Section 409A and guidance thereunder, although requirements dealing with form and time of payment still had to be contained in documents by December 31, 2007.
The Internal Revenue Service has now issued a new notice extending until December 31, 2008 the deadline for amending plans to comply with all aspects of Section 409A. The new notice also extends transition rules until December 31, 2008 with respect to the following issues:
Please contact us to discuss the impact of this new notice on the applicable plans and arrangements your company maintains.
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Schiff Hardin Employee Benefits and Executive Compensation Group
Schiff Hardin LLP