Update on Code Section 457A: New Guidance, But Uncertainties Remain
The IRS, on January 9, 2009, issued Notice 2009-8 (the "Notice"),
its initial guidance interpreting Section 457A, which was enacted
on October 3, 2008 as part of the Emergency Economic
Stabilization Act of 2008 and which generally became effective
January 1, 2009.[1]
We have prepared the attached detailed analysis of the Notice to
assist multinational employers in understanding Code Section
457A, given not only the potentially broad impact, but also the
limited transition period (until July 1, 2009, in some cases, and
December 31, 2011, in other cases) to make certain conforming
amendments.