IRS Updates Audit Guide for Nonqualified Plans

The IRS recently updated its Nonqualified Deferred Compensation Audit Techniques Guide. The updated June 2021 Guide (the “2021 Guide”) replaces the previous version published in June 2015 (the “2015 Guide”), and provides a notable expansion of the details surrounding the legal standard applied in reviewing Nonqualified Deferred Compensation (“NQDC”) plans, with an increased emphasis on Internal Revenue Code (“Code”) section 409A (“Section 409A”). READ MORE