Employee Benefits and Executive Compensation Advisory: Guidance Issued on Reporting and Wage Withholding under Code § 409A
12/21/2006
Recently issued IRS Notice 2006-100 provides important new rules clarifying the reporting and wage withholding treatment of deferred compensation arrangements for 2005 and 2006. While this guidance provides some welcome relief (e.g., the requirement that 2005 deferrals not be reported is extended to 2006), there is a premium placed on compliance for other purposes (e.g., the waiver of certain late filing and payment penalties). This Mintz Levin Advisory explains the key features of this recent guidance and the steps that plan sponsors need to take in response.
