The Treasury Department’s proposed regulations regarding the income tax treatment of “ineligible plans” of tax-exempt employers under Code Section 457(f), published in June 2016, were greeted with much fanfare. (Final regulations have not yet been published, but taxpayers may rely on the proposed regulations now.) Section 1.457(f)-12 of the proposed regulations (the “Proposed Regulations”) attempts to fill in the gaps, and iron out some of the inconsistencies, between the general rules governing deferred compensation plans under Code Section 409A and the special rules governing “ineligible plans” (“Section 457(f) plans”). READ MORE