As noted in prior DWT advisory bulletins, the IRS has repeatedly extended the deadline for amending plan documents to comply with Section 409A. Although most employers have already completed any needed plan amendments, or are well on their way to completion, there is still time (but just barely) for those who may have delayed taking action. In short, if you have put off your 409A compliance until the last minute, it is now the last minute.
For a summary of steps that should be taken, see our prior advisory bulletin. If you need assistance, contact one the attorneys below without delay.