Employee Benefits Alert: Section 409A Compliance: A Second Bite at the Apple Ends December 31st
11/9/2010
Section 409A of the Internal Revenue Code (“Section 409A”), which regulates non-qualified deferred compensation arrangements, was signed into law in 2004 and went into effect January 1, 2005. Not only did Section 409A establish many new requirements for deferred compensation, but it also expanded the traditional notion of deferred compensation to include, among other arrangements, bonus plans, reimbursement policies, severance agreements, change in control agreements, and employment agreements.
