Chief Counsel Memorandum Clarifies IRS Position on Informal 409A Corrections
On May 1, the IRS released a Chief Counsel Memorandum that clarifies the IRS’ position with respect to the correction of deferred compensation arrangements outside of the IRS’ formal Section 409A correction programs. In the Memorandum the IRS analyzed a retention bonus that was granted in year 1, vested in year 3, and to the […]
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2 min read
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Tagged: 409A, 409A failures, correction, deferred compensation, deferred compensation arrangements, Section 409A
GG
Greg Gautam
Partner