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NQDC |
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409A(d)(1) defines a NQDC plan as "any plan that provides for the deferral of compensation, other than (A) a qualified employer plan, and (B) any bona fide vacation leave, sick leave, compensatory time, disability pay, or death benefit plan. It is assumed that 401(k) providers are just as up-to-date on and experienced with NQDC plans as those companies specializing in this area. Though the NQDC provisions generally are effective for post-2004 deferrals, the new law clarifies that the effective date of the Sec. |
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