Employee Benefits Client Advisory: Notice 2005-1: IRS Issues Initial Guidance Governing Non-Qualified Deferred Compensation Under Code §409A
1/5/2005
The American Jobs Creation Act of 2004 radically restructures the tax treatment of non-qualified deferred compensation. The Act provides a clear - if limiting - set of rules together with explicit directions to the U.S. Department of the Treasury and the Internal Revenue Service to issue guidance to flesh out the rules. Not covered are many of Code §409A's formal requirements and operational rules.
Set out in this publication are some of the more important highlights of the Act.
