Benefits Alert: Navigating the Code § 409A Transitional Rules
10/25/2005
In Notice 2005-1, the IRS and Treasury first announced transition rules governing the treatment of deferred compensation arrangements under the American Jobs Creation Act of 2004, which enacted new Code § 409A. A recently proposed Treasury regulation furnished additional guidance expanding some but not all of the Notice 2005-1 transition rules.
This Advisory explains the Code § 409A transition rules as embodied in both Notice 2005-1 and the proposed rule.
