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Section 409A Document Correction Relief: Take the Final Bite of the Apple before December 31st

My colleagues, Tom Greene and Jessica Catlow, have published an alert pertaining to Section 409A of the Internal Revenue Code (Section 409A), which regulates the payment of non-qualified deferred compensation (including that provided through severance agreements) and imposes penalties for non-compliance.  In January 2010,  the IRS issued Notice 2010-6, which provided an opportunity to correct certain documentary violations in order to reduce or avoid the adverse tax consequences under Section 409A.  The relief provided under Notice 2010-6, which was extended under IRS Notice 2010-80, is set to expire on December 31, 2012.  To read the full alert, click here.

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Martha Zackin