409A

Proposed Section 409A Regulations Published

Topics: 409A, COLI/BOLI

The IRS recently issued proposed regulations supplementing the existing regulations and guidance on the application of Code Section 409A to nonqualified deferred compensation arrangements. As a whole, the proposed regulations clarify existing rules rather than making substantive changes to Section 409A. The proposed regulations will become effective when they are published as final regulations.

Better Consult the Oracle: 8 Key Questions for Code § 409A Compliance – The Gatekeeper to Structuring Effective Deferred Compensation Arrangements.

Topics: 409A, COLI/BOLI, NQDC

Thursday, June 11, 2015WRM#15-21 The WRMarketplace is created exclusively for AALU Members by the AALU staff and Greenberg Traurig, one of the nation’s leading tax and wealth management law firms. The WRMarketplace provides deep insight into trends and events impacting the use of life insurance products, including key take-aways, for AALU members, clients and advisors.…

Nonqualified Deferred Compensation Section 409A Compliance

Topics: 409A, COLI/BOLI, NQDC

A Chief Counsel Advice memorandum of the Internal Revenue Service advises that a pre-vesting plan correction will not “save” a nonqualified deferral plan’s failure to comply with Section 409A of the Internal Revenue Code (“Section 409A”) if benefits vest before the last day of the tax year in which the correction was made.

IRS Announces New Program to Audit 409A Compliance

Topics: 409A, COLI/BOLI, IRS, Regulation

The IRS is getting ready to ramp up enforcement of Section 409A compliance with respect to non-qualified deferred compensation arrangements. This new compliance initiative project (“CIP”) for Section 409A will focus on fifty large companies. However, this foreshadows a much broader Section 409A enforcement initiative.

IRS Announces New Program to Audit 409A Compliance

Topics: 409A, COLI/BOLI, IRS, Regulation

The IRS is getting ready to ramp up enforcement of Section 409A compliance with respect to non-qualified deferred compensation arrangements. This new compliance initiative project (“CIP”) for Section 409A will focus on fifty large companies. However, this foreshadows a much broader Section 409A enforcementinitiative.