New Guidance on §457A Rules for Compensation Payable by Partnerships and Non-U.S. Corporations: IRS Confirms it Wasn’t a Bad Dream

14 January 2009
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This memo discusses the IRS issued Notice 2009-8, which provides interim guidance on how it intends to apply the new Section 457A of the Internal Revenue Code.  This new provision applies even if the deferred compensation arrangement complies with the stringent deferred compensation rules under Section 409A.