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<nobr>Jan 4, 2006</nobr>
ERIC Submits Comments to Treasury 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 is below. If you have any questions, please contact Vanessa Scott at vscott@eric.org.
Text Files:
ERIC 409A Comments Jan 2006
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