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IRS expands areas collateral to 409A arrangements in which advance rulings or determination letters will be considered

Summary The IRS has released a revenue procedure updating Rev. Proc. 2008-3, which expands areas collateral to the tax consequences of Code Sec. 409A arrangements in which IRS will consider issuing an advance ruling or determination letter.

This revenue procedure modifies and amplifies Rev. Proc. 2008-3, 2008-1 I.R.B. 110, with respect to areas in which rulings and determination letters will not be issued as to the tax consequences of arrangements described in § 409A of the Internal Revenue Code. As described below, this revenue procedure does not provide for the Service to issue rulings on the application of § 409A to nonqualified deferred compensation plans, but does provide for the issuance of rulings in other areas with respect to compensation plans that may covered by § 409A.

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