On October 22, 2004, President Bush signed the American Jobs Creation Act of 2004, including new Internal Revenue Code Section 409A. Section 409A dramatically changes the nonqualified deferred compensation landscape. The new rules are effective on January 1, 2005 and require immediate attention to many plans.
The teleconference discussed the new rules and provided guidance on what employers should do while awaiting further IRS guidance. In the coming months, we expect to present additional sessions for each of our for-profit and tax-exempt clients to discuss the IRS guidance.
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