Section 409A Reminder and Update

Secction 409A of the Internal Revenue Code was added by the American Jobs Creation Act of 2004.¹ On April 17, 2007,² the Internal Revenue Service issued final regulations—nearly 400 pages in length—which took effect Jan. 1, 2008.³ Together, IRC Section 409A and the final regulations provide a comprehensive set of rules regulating the taxation of nonqualified deferred compensation (NDC). Since its enactment, S