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The following is not meant to be legal advice.

Announcement 2007-18 (the “Announcement”) implements a compliance resolution program for employers The program allows the employer to report and pay the additional 20% income tax and interest charge under Section 409A due from employees, other than certain Section 16(a) reporting persons, that result from employee exercises of these discount stock rights during 2006. The program places the burden on the employer to pay the additional Section 409A taxes for the rank-and-file employees covered by the program.