Nonqualified Deferred Compensation Plans: Don’t Ignore All of the Other Rules

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Nonqualified Deferred Compensation Plans the other rulesIn a blog post  released this past Monday and authored  by Michael S. Melbinger of Winston & Strawn LLP, Melbinger takes a closer look at the recently released IRS Audit Technique Guide for Nonqualified Deferred Compensation Plans. 

Noting that the headline about the release “looked promising,” and that this is the first IRS update since 2005, Melbinger said, “The new Audit Technique Guide (ATG) leaves the impression that 409A is only a minor concern for the IRS auditors of nonqualified deferred compensation plans.”

Melbinger then goes on to observe that perhaps the IRS is trying to send the warning that one shouldn’t ignore all the other rules that apply to nonqualified deferred compensation plans and points out key areas that should not be overlooked. Follow this link to read the article in full: IRS releases nonqualified deferred compensation audit techniques guide.

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