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About this Blog
Welcome to the Snell & Wilmer Benefits Blog. We will be posting about current employee benefits and executive compensation topics and issues. We invite you to contact the authors with your thoughts or questions.Blog Contributors
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Short-Term Deferral Day is Right Around the Corner
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A provides that a payment will not be considered nonqualified … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, annual incentive, Code Section 409A, deadline, deferred compensation, Internal Revenue Code, IRC, March 15, short term deferral
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Updated Nonqualified Deferred Compensation Plan Audit Guide
In June the Internal Revenue Service released an updated Nonqualified Deferred Compensation Audit Technique Guide. This updated Guide replaces the initial Guide published in 2015. While it is too early to say whether the release of the updated guidance signals … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, nonqualified deferred compensation, Section 409A
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Salary Deferrals in the Time of COVID-19
As the saying goes, “drastic times call for drastic measures” and, from an economic standpoint, these are drastic times. To fight the battle to stay in business many employers are considering a wide range of alternatives, including employee furloughs, layoffs … Continue reading
Posted in Employee Benefits, Executive Compensation, Qualified Retirement Plans
| Tagged 409A, coronavirus, covid-19, deferred compensation, pandemic, salary deferral
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Short-Term Deferral Day is Right Around the Corner
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A provides that a payment will not be considered nonqualified … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, deferral exception, March 15, Section 409A, short-term deferral
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Reminder that Nonqualified Deferred Compensation Deferral Elections for 2018 Must be Made on or Before December 31, 2017
As we approach the end of 2017, we want to remind employers and employees to take action before year end if they desire to defer compensation that will be earned during 2018. As a general rule, Section 409A of the … Continue reading
Posted in Employee Benefits
| Tagged 409A, deferral election, nonqualified deferred compensation, Section 409A
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IRS Audit Techniques Guide Provides Helpful Reminders for Sponsors of NQDC Arrangements
Last summer the Internal Revenue Service updated its Audit Techniques Guide (“ATG”) for nonqualified deferred compensation arrangements. While the ATG provides little instruction on how the IRS will review nonqualified deferred compensation arrangements for compliance with Section 409A of the … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, ATG, Audit Techniques Guides, deferred compensation, FICA, FUTA, Internal revenue service, IRS, nonqualified deferred compensation, Section 409A
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Chief Counsel Memorandum Clarifies IRS Position on Informal 409A Corrections
On May 1, the IRS released a Chief Counsel Memorandum that clarifies the IRS’ position with respect to the correction of deferred compensation arrangements outside of the IRS’ formal Section 409A correction programs. In the Memorandum the IRS analyzed a … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, 409A failures, correction, deferred compensation, deferred compensation arrangements, Section 409A
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Don’t Miss Short-Term Deferral Day
Section 409A, the provision of the Internal Revenue Code that regulates the time and form of payment of nonqualified deferred compensation, contains a helpful exception for “short-term deferrals.” Specifically, Section 409A provides that a payment will not be considered nonqualified … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, equity-based compensation, Executive Compensation, Incentive Plans, nonqualified deferred compensation, Performance-Based Compensation, short-term deferral
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Deferral Elections for 2015 Compensation
As reported in Part 3 of our 2014 End of Year Plan Sponsor “To Do” List, employers that sponsor deferred compensation programs should take action to ensure that deferral elections that apply to compensation that will be earned in 2015 … Continue reading
Posted in Employee Benefits, Executive Compensation
| Tagged 409A, deferral election, Executive Compensation
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Subsidized Post-Termination COBRA Benefits
Nancy Campbell recently wrote a newsletter that discussed how health care reform impacts COBRA. One of the issues that Nancy addressed is subsidized COBRA and severance arrangements. The purpose of this blog is to dive deeper into the issues employers … Continue reading
Posted in Employee Benefits, Health & Welfare Plans, Health Care Reform
| Tagged 409A, COBRA, Health Care, health care reform, health plans, post-termination medical, severance
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