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ARTICLE · 01 SEPTEMBER 2008

IMPORTANT REMINDER! - Section 409A Deferred Compensation Compliance Deadline Rapidly Approaching

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The time to bring ALL deferred compensation arrangements into final compliance with new requirements of federal law is rapidly approaching!

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The time to bring ALL deferred compensation arrangements into final compliance with new requirements of federal law is rapidly approaching! Failure to act now could result in the imposition of severe tax penalties. Under the new law (known as "Section 409A" of the Internal Revenue Code), deferred compensation includes a wide variety of arrangements, many of which are not commonly thought to provide deferred compensation. We have listed below some of the arrangements that may be subject to the new requirements. The final compliance deadline is December 31, 2008.

We strongly recommend that you promptly contact your advisors concerning this approaching deadline. While Section 409A has been in effect since January 1, 2005, beginning on January 1, 2009, all arrangements that are subject to Section 409A (including verbal agreements) must be in a written document that complies with the requirements of

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