on September 10, 2007, the IRS issued Notice 2007-78 (the "Notice") and granted limited relief for bringing nonqualified deferred compensation plans into written compliance with Section 409A of the Internal Revenue Code. However, the Notice still requires most major decisions be made and documented before December 31, 2007.
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.
