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The Law<br />

• American Jobs Creation Act of 2004<br />

created Section 409A of the Internal<br />

Revenue Code<br />

• IRS Guidance<br />

– Notice 2005-1 on December 20, 2004<br />

– Proposed Regulations on September 29, 2005<br />

– Notice 2006-4 on December 28, 2005<br />

– F<strong>in</strong>al Regulations expected this summer to be<br />

effective January 1, 2007<br />

3

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