Tax Rules Governing Deferred Compensation, 409A, Focused on the Least Important Policy Considerations and Ignore the Most Important

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=969058

"The tax rules governing deferred compensation, codified at section 409A, are harsh and complex. The rules are focused on the least important policy considerations and overlook the most important. Professors Halperin and Yale suggest a different approach, one that would make the law simpler, fairer, and more effective."