Proposed Regulations on Calculation of Includible Income in Failed Section 409A Arrangement

In addition to the wealth of other guidance recently issued, the IRS has issued proposed regulations governing the determination of includible income, the application of the 20% additional tax and premium interest in the case of a Section 409A arrangement that fails to satisfy the requirements in form or operation.

Document Excerpt

This document contains proposed regulations on the calculation of amounts includible in income under section 409A(a) and the additional taxes imposed by such section with respect to service providers participating in certain nonqualified deferred compensation plans. The regulations would affect such service providers and the service recipients for whom the service providers provde services. 



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