Non-Qualified Deferred Compensation Basics:  Foundations of Code Section 409A 

Thursday, May 26, 2005

A 90-minute TeleConference/Live Audio Webcast

1:00-2:30 pm ET / 12:00-1:30 pm CT / 11:00 am-12:30 pm MT / 10:00 am-11:30 am PT

The enactment of Section 409A of the Internal Revenue Code represents a massive shift in the rules governing non-qualified deferred compensation.  Code Section 409A, however, is intended to overlay a legal foundation that developed in case law and agency rulings for years prior to the enactment of Code Section 409A.  This foundation consists, among other things, of the rules governing transfers of property under Code Section 83 and the doctrines of constructive receipt and economic benefit.  An understanding of these foundational rules and how they apply now is essential to understanding Code Section 409A. TOPICS:    

·  In case you missed it the first time around, the law of non-qualified deferred compensation before Code Section 409A

· What''s left of these doctrines post-Code Section 409A

·  Refresher on how Code Section 83 and the constructive receipt doctrine work

·  To which compensation vehicles do Code Section 83 and the constructive receipt doctrine still apply 

• Review the rules that apply to plans "grandfathered" under Code Section 409A

Moderator: 

Joni L. Andrioff, Jones Day, Chicago, IL

Speakers: 

Elizabeth Drigotas, Deloitte Tax LLP, Washington, DC

Catherine L. Fernandez, Branch Chief, Executive Compensation, IRS Office of Association Chief Counsel, Washington, DC

David M. Weiner, Chicago, IL

***Checks should be made payable to ABA-JCEB and mailed to 740 15th Street, NW, Washington, DC  20005.***

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