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Abstract: 

In Private Letter Ruling 200905016, a corporate employer adopted a nonqualified deferred compensation plan (Plan) for a group of highly compensated employees. Under the Plan, participating employees may defer a specified percentage or dollar amount of their incentive compensation. Amounts deferred become payable when the employee dies or is ceases to be employed, or upon termination of the Plan. Each employee may designate one or more beneficiaries to receive all or part of his or her deferred compensation in the event of the employee’s death.

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