Current Events - Rock 'n Roll, Gaming, Corvettes and Compliance Deadlines

This is quite a run we're on. SIRIUS Radio gives us a 24/7 AC/DC channel. Rock Band 2 (with crazy-cool aftermarket drum sets) comes out. Press reports on the new 638-hp Corvette Z06 proliferate. What could possibly top all that?

Well, straight from the "Inside Washington" portion of the TMCPJ, they get us all excited with the following teaser:

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The final regulations under §409A were originally supposed to be effective on January 1, 2008. Due to strenuous objections from practitioners [(thanks again, Regina)], the IRS delayed the effective date of those regulations until January 1, 2009.

A number of practitioners have heard rumors that consideration is being given to a further delay in the effective date of the §409A regulations.
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Yeah . . . ? Yeah . . . ? Could there be more? Could there? Could there? News of a further extension almost could rival the music, gaming and automotive news noted above (well, not really, but . . .).

Oh, well - to paraphrase Cameron Diaz in There's Something About Mary, they were just foolin' with us. The next lines in the Item say:

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The JOURNAL understands that any further delay in that effective date is very unlikely because the IRS feels that companies and practitioners have now had sufficient time to deal with the issues and that further delay is not necessary.
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You can almost hear SNL's Debbie Downer music going "waaa waaaaaa" in the background. So deflating. Oh, well - back to 409A compliance reviews. . . .

Before leaving Inside Washington, though, it's worth noting generally that the Items therein may well be among the most useful diamonds in the rough out there. They actually can make you sound pretty smart and tuned in. Sometimes over the years I have had only a TMCPJ Item to point to when in need of support for a proposition or when wanting to bolster a cautionary approach regarding an issue. Sometimes, an Item alerts me to an issue or problem that had not otherwise surfaced for me. And sometimes, concrete information is available in an Item and not readily available generally, as was the case recently when an Item alerted readers to the 162(m) PLR that indicated a reversed IRS position on certain critical vesting-type issues relating to performance-based compensation. The 162(m) PLR, when ultimately released, led to quite the commotion earlier this year (2008), and eventually to a Revenue Ruling with transition relief. For those who had focused on the advance notice that had somehow made its way into Inside Washington, it was nice (and maybe even useful) to have had prior knowledge that the ruling was coming down the pike.