The Internal Revenue Service and the Treasury Department issued a notice that allows taxpayers to make corrections for operational failures in complying with rules for nonqualified deferred compensation, but only when the failures are unintentional.
Notice 2007-100 provides relief for certain operational failures that are corrected in the same year. The notice also provides transition relief through 2010 for operational failures up to a certain amount that are not corrected in the same taxable year by limiting the amount of income inclusion and additional taxes.
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