This Executive Alert describes how the rules contained within the final regulations promulgated under Section 409A of the Internal Revenue Code (the "Code") impact the global workforces of U.S.-based companies with operations abroad and foreign-owned companies with operations in the U.S. The Section 409A rules add additional considerations when deferred compensation arrangements are extended to U.S. citizens for work abroad, resident aliens, nonresident aliens and certain bona fide residents of U.S. possessions. Specifically, this Alert highlights major changes the final regulations published on April 10, 2007, (the "Final Regulations") made to the rules previously set forth in the proposed regulations that were published by the U.S. Treasury and Internal Revenue Service on September 29, 2005 (the "proposed regulations").
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