AICPA Comments on Notice 2007-100, Recommendations for a Section 409A Correction Program 

    Published July 01, 2008

    This document describes AICPA’s comments on Notice 2007-100 and offers the following six recommendations for a permanent correction program:

    1. Extending the deadlines for correcting operational errors
    2. Removing the relatively low $15,500 limit for operational errors not corrected within the taxable year
    3. Replacing the requirement that operational errors be “unintentional” with an “egregious error” standard
    4. Allowing taxpayers other than company insiders to use the self correction program even if their tax returns are under IRS examination
    5. Allowing certain plan document errors to be corrected
    6. Allowing certain failures with respect to stock rights to be corrected

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