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32 PROBATE & PROPERTY NOVEMBER/DECEMBER 2007 Section 409Aof the Internal Revenue Code (“Code”) became effective on January 1, 2005. Because of transitiio relief and postponements of the deadline for adopting amendments, many companies, executives, and their advisers have not paid full attention to its effects and requirements. The final regulations issued in April 2007 proviid that the transition relief ends on December 31, 2007. The amendment deadline has been extended until December 31, 2008...

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