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:

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

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