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Jan 4, 2006
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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