<nobr>Jan 4, 2006</nobr>

ERIC Submits Comments on 409A Proposed Regulations

ERIC submitted its comments to Treasury and the IRS on the proposed 409A regulations on January 3, 2006. The comments cover a broad range of issues addressed in the proposed regulations issued on October 4, 2005, including:

* the treatment of nonstatutory stock options;
* application of section 409A to fringe benefit arrangements;
* foreign plans;
* application of the short-term deferral rule;
* rules regarding deferral elections;
* treatment of of performance-based compensation;
* benefit restoration and wrap-around plans;
* severance pay plans;
* distribution triggers (including termination of employment, change in control, plan termination and disability);
* distribution options; and
* transition provisions.

A copy of ERIC's comments are attached. If you have any questions, please contact Vanessa Scott at vscott@eric.org.

Text Files:

ERIC 409A Comments Jan 2006

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