The new requirements relating to deferred compensation under section 409A of the Internal Revenue Code are effective January 1, 2005. Although the due date for amending plans to comply with section 409A is generally December 31, 2006, there are several earlier compliance dates under the proposed Treasury regulations. Plans have to be administered in compliance with section 409A as of January 1, 2005, and certain plan amendments and actions have to be made or taken by December 31, 2005.
