In this highly technical area, our group is widely known for their inventive and practical approach to solving problems and resolving business issues. Our team provides advice in connection with high-profile, multibillion-dollar M&A transactions, public proxy statements, compensation arrangements and ERISA fiduciary matters for investment funds and plan fiduciaries.
Code Section 457A: Deadline Alert and Review
June 16, 2009 Read the memo
June 30, 2009 is the deadline for taking advantage of some special relief granted by the Internal Revenue Service in guidance released last January under Internal Revenue Code Section 457A (IRS Notice 2009-8). A second elective relief provision carries a December 31, 2011 deadline. The June 30 deadline is likely of greatest interest to hedge funds that failed to fully service-vest old offshore deferrals before the end of 2008 but would now like to take greater advantage of Section 457A's grandfathering rules. This client alert revisits the Section 457A rules, describes IRS Notice 2009-8 and the special elections for transition relief and supplements our October 20, 2008 client alert on Section 457A.