The IRS has issued a proposed rule related to requirements applicable to nonqualified deferred compensation plans (NDCPs) under tax code section 409A. Clarifications and modifications could help taxpayers comply with these requirements. Compliance with the 409A requirements enables individuals covered by and employers sponsoring NDCPs to avoid adverse tax treatment of the amounts payable under these arrangements. The proposed rule covers a diverse range of topics. This bulletin focuses on four key areas that may have the broadest application to NDCP sponsors.