Jenner & Block

Client Advisory: IRS Provides Relief If Certain Section 409A Document Failures Are Corrected By Year-End and Issues Guidance on Deducting Contingent Bonus Compensation

In this client advisory, Partner Raymond D. Sinnappan and Associate Gregory M. Wu discuss Notice 2010-6 issued by the IRS on January 5, 2010, which offers guidance on correcting certain document failures under Section 409A of the Internal Revenue Code and provides corresponding transition relief.  The authors also address guidance from the IRS on when a company can take a deduction for contingent bonus compensation.