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New IRS Guidance Provides Only Limited Relief From Looming Section 409A Deadline
09/11/2007

Yesterday, the IRS released Notice 2007-78, providing limited transition relief from the looming December 31, 2007 deadline for compliance with Internal Revenue Code Section 409A, which imposes significant operational and documentation requirements on deferred compensation arrangements. The Notice extends the deadline for full document compliance until December 31, 2008. However, what the Notice does not do is even more important:


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