Late last month the Internal Revenue issued Notice 2006-79, which postpones the effective date of final regulations for non-qualified deferred compensation under IRC 409A until January 1, 2008. (The original regulations, published in October 2005, proposed a January 1, 2007 effective date). “Although the IRS and Treasury Department expect to issue the final regulations before the end of 2006,” the Notice provides “transitional relief” for taxpayers to analyze and come into compliance with the final 409A provisions.
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