The Treasury Department and the Internal Revenue Service have issued proposed regulations regarding the application of Section 409A of the Internal Revenue Code to nonqualified deferred compensation plans or arrangements.
On October 22, 2004, President Bush signed the American Jobs Creation Act which has created the need for significant changes to many nonqualified deferred compensation plans and arrangements before the end of 2004.
On May 19, the Department of Labor ("DOL") issued a Field Assistance Bulletin (FAB 2003-3) that significantly changes the DOL's position on charging participants' accounts for certain plan-related expenses.
Our Client Alert (in PDF format) details the DOL's new position.
