Provided by Tara Silver-Malyska of Grant Thornton HERE
"IDRs have included requests such the following:
Provide a list of all plans and arrangements that provide an employee with a legally binding right to compensation in one year, but payment in a subsequent year
Provide the basis for the position that the arrangement(s) is not subject to Section 409A, e.g., the short-term deferral rule, if applicable
Identify the terms of the nonqualified deferred compensation plan’s elections, including the deadline for the elections
If a payment was deferred beyond the originally scheduled payment date, identify the terms, including the payment date and the rescheduled payment date
Identify any acceleration in payments, including transition relief elections and deadlines, the original payment and actual payment dates
Identify “specified employees” and any payments of nonqualified deferred compensation made to specified employees within six months after separation from service
Provide a description of the plan and each modification made to comply with Section 409A
Identify and describe Section 409A violations and if such amounts were reported on a W-2 or Form 1099
Identify participation in any correction programs
Provide certain information on stock options and SARs that may be subject to Section 409A
Provide a description of any nonqualified deferred compensation funding resulting from a decline in the company’s financial condition"
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1 comment:
I think it it is perfect getting these transition relief elections and deadlines i think it is the perfect proposal to reach what they want.
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