Employee Benefits and Executive Compensation Update

October 26, 2007

SECTION 409A AMENDMENT AND TRANSITION DATES EXTENDED TO DECEMBER 31, 2008

The Internal Revenue Service had previously extended to December 31, 2008 the date for nonqualified deferred compensation plans and arrangements to be amended to comply with most of the provisions of Section 409A and guidance thereunder, although requirements dealing with form and time of payment still had to be contained in documents by December 31, 2007.

The Internal Revenue Service has now issued a new notice extending until December 31, 2008 the deadline for amending plans to comply with all aspects of Section 409A. The new notice also extends transition rules until December 31, 2008 with respect to the following issues:

1.	Changes to the time and form of payment of deferred amounts,
2.	Payment elections under a nonqualified deferred compensation plan that are linked to elections under a qualified plan,
3.	The substitution of non-discounted stock options and stock appreciation rights for discounted stock options and stock appreciation rights, and
4.	The time to amend a plan to comply with certain deferral elections made on or before March 15, 2005 under a previous Internal Revenue Service transition rule.

Please contact us to discuss the impact of this new notice on the applicable plans and arrangements your company maintains.

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Schiff Hardin Employee Benefits and Executive Compensation Group


Lauralyn G. Bengel 312.258.5670	Edward Spacapan Jr. 312.258.5788
Glenn D. Gunnels 404.437.7012	Margaret A. Strothkamp 312.258.5620
Robert E. Lesser 404.437.7051	David H. Williams 404.437.7010
Neal A. Mancoff 312.258.5699

Schiff Hardin LLP

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