2007 Deadline For Deferred Compensation Plan Amendments Under Section 409a Final Regulations

On April 10, 2007 the Department of the Treasury and the Internal Revenue Service issued final regulations on nonqualified deferred compensation under Section 409A of the Internal Revenue Code (the "Final Regulations"). The long awaited Final Regulations are generally effective as of January 1, 2008. Employers have until December 31, 2007 to conform all deferred compensation plans, awards, agreements and other covered arrangements to Section 409A and the Final Regulations. A special effective date rule applies to certain collectively bargained non-qualified deferred compensation arrangements. Plan sponsors may continue to operate their deferred compensation plans in accordance with a reasonable good faith interpretation of the proposed regulations and other interim guidance through December 31, 2007.