The IRS has commenced a compliance initiative project (“CIP”) aimed at nonqualified deferred compensation arrangements subject to Section 409A of the Internal Revenue Code (“409A”). Although the project scope is limited, employers with arrangements that may be subject to 409A should take this regulatory action as a prompting to review their arrangements and make any

The Internal Revenue Service has announced its Voluntary Classification Settlement Program (“VCSP”) offering relief to certain employers from unpaid employment taxes, penalties and interest that may result from misclassification of workers.  The IRS’s September 21, 2011, Announcement 2011-64 and “Frequently Asked Questions” (published on September 30) explains that the VCSP allows employers to correct misclassification