Wednesday, December 26, 2007

IRS Notice 2007-100 - Transition Relief and Guidance on Corrections of Certain Failures of a Nonqualified

Part III – Administrative, Procedural, and Miscellaneous

IRS Notice 2007-100 - Deferred Compensation Plan to Comply with § 409A(a) in Operation
This notice provides transition relief and guidance on the correction of certain failures of a nonqualified deferred compensation plan to comply with section 409A(a) of the Code in operation (an operational failure), including: (1) methods for correcting certain operational failures during a service provider’s taxable year in which the failure occurs to avoid income inclusion under section 409A(a); (2) transition relief limiting the amount includible in income under section 409A(a) for certain operational failures occurring in a service provider’s taxable year beginning before January 1, 2010, that involve only limited amounts; (3) an outline of, and request for comments on, a potential corrections program that would permit service recipients and service providers to limit the amounts required to be included in income under section 409A(a) due to certain operational failures.

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