Section 409A Compliance Failure Document Corrections Program Issued

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IRS issues Notice 2010-6 establishing a document corrections program under tax code Section 409A. Notice 2010-6 provides guidance on eligibility requirements, types of documentary failures that may be corrected, information and reporting requirements, and transition relief. Notice 2010-6 is effective for taxable years beginning on or after Jan. 1. Under the notice, relief is not available if the federal tax return of the employer or the federal tax return of the employee is under examination, if the failure is intentional, or if the failure is related to a listed transaction.