IRS Announces New Program to Audit 409A Compliance


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The IRS is getting ready to ramp up enforcement of Section 409A compliance with respect to non-qualified deferred compensation arrangements. This new compliance initiative project (“CIP”) for Section 409A will focus on fifty large companies. However, this foreshadows a much broader Section 409A enforcement initiative.
The Service plans to issue Information Document Requests (“IDRs”) to about 50 large employers. These initial IDRs will request documents regarding deferred compensation
elections and payouts. The IRS informally indicated that these will focus on three issues: 1) initial deferral elections, 2) subsequent changes in deferral elections and, 3) timing of payouts.
Requested data will initially be limited to the top 10 highest paid employees in each company.
Information gained from the first 50 audits will be used by the IRS to target future 409A audit and enforcement activity.

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IRS Announces New Program to Audit 409A Compliance

  1. 1. IRS Announces 2015 Retirement Plan Limits Ponte Vedra Beach, FL -- (October 23, 2014) -- The IRS announced today the cost of living adjustments for qualified pension and defined contribution plans. The important retirement plan limits for 2014 and 2015 are summarized below: 2015 2014 Elective Deferral Limit for 401(k) and 403(b) Plans $18,000 $17,500 Age 50 Catch Up Limit for 401(k) and 403(b) Plans $6,000 $5,500 415 Defined Contribution Plan Limit $53,000 $52,000 Qualified Compensation Limit $265,000 $260,000 Highly Compensated Employee Limit $120,000 $115,000 Key Employee Officer Compensation Limit $170,000 $170,000 Social Security Taxable Wage Base $118,500 $117,000 About Fulcrum Partners LLC : Fulcrum Partners LLC ( is one of the nation's leading and largest executive benefits consultancies. A team of experienced industry professionals, the consultants at Fulcrum Partners focus on an integrated approach to the design, financing, and plan administration of executive benefits programs. Fulcrum Partners
  2. 2. LLC is a wholly independent, member-owned firm dedicated to helping organizations enhance their Total Rewards Strategy. Founded in Ponte Vedra Beach, FL in 2007, today the company has offices in Atlanta; Chicago; Charleston, (South Carolina); Columbus, (Ohio); Delray Beach, Florida; Honolulu; Houston; Los Angeles; Orlando; Ponte Vedra Beach, (Florida); Portland, (Oregon); and Washington D.C. Bruce Brownell 904.296.2563 Securities offered through Registered Representatives of ValMark Securities, Inc. Member FINRA, SIPC, 130 Springside Drive, Suite 300, Akron, OH 44333-2431, Tel: 1-800-765-5201. Investment Advisory Services offered through ValMark Advisers, Inc., which is an SEC Registered Investment Advisor. Fulcrum Partners LLC is a separate entity from ValMark Securities, Inc. and ValMark Advisers, Inc.