Excerpt from Practical Guidance

Section 409A And Deferred Compensation Arrangements

By Sinead Kelly and Narendra Acharya (October 6, 2017, 2:45 PM EDT) -- Since its initial effectiveness in 2005, Internal Revenue Code Section 409A has dramatically altered the design and operation of nonqualified deferred compensation arrangements with U.S. employees and other service providers. Because the U.S. taxes its citizens and residents on a worldwide income basis, it is important to remember that Section 409A does not stop at the U.S. borders and instead applies to U.S. taxpayers wherever they may be....

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