Understanding the New Section 409A Plan Document Correction Program

The “document correction program,” as the IRS refers to it in Notice 2010-6, is intended to motivate taxpayers to review nonqualified deferred compensation plans in order to identify and correct any provisions that fail to comply with Section 409A. This white paper by Manager Jeffrey A. Martin and Partner G. Edgar Adkins, Jr., in our Washington National Tax Office explores the various provisions of the correction program, including eligibility requirements, written document failures that can be corrected, actions and reporting requirements that apply to all document failures corrected under the program, and special amendment period and transition relief

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