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ARTICLE · 20 SEPTEMBER 2007

IRS Delays Some Requirements Of Code Section 409a

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On August 21, 2007, Bracewell & Giuliani LLP, along with 91 peer law firms across the U.S., issued a letter to the IRS requesting an extension of the deadline for amending deferred compensation plans, agreements and arrangements required to comply with Internal Revenue Code Section 409A (Deferred Compensation Plans).

United StatesEmployment and HR
Bracewell LLP
Bracewell LLP
Scott Sanders
Scott Sanders
Michael Tomberg
Michael Tomberg

On August 21, 2007, Bracewell & Giuliani LLP, along with 91 peer law firms across the U.S., issued a letter to the IRS requesting an extension of the deadline for amending deferred compensation plans, agreements and arrangements required to comply with Internal Revenue Code Section 409A (Deferred Compensation Plans). The letter requested an extension to December 31, 2008 to bring plan documents into compliance with Code Section 409A and also requested an extension of the transition relief period until December 31, 2008.

On Monday, September 10, 2007, the IRS, in response to the joint request, issued Notice 2007-78 which delays only certain documentary compliance requirements until December 31, 2008, but does not extend the transition relief period past December 31, 2007.

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