409A and Non-U.S. Arrangements

http://www.mercer.com/referencecontent.jhtml?idContent=1296475

"Although there are lengthy compliance requirements to avoid the tax consequences, a number of potential exemptions are available to non-US plans. These exemptions are quite complex and are discussed in the article."

409A: "Intelligent Design" and Linked Plans

http://www.jpmorgan.com/cm/Satellite?c=JPM_Content_C&cid=1159337371619&pagename=jpmorgan/am/JPM_Content_C/Generic_Detail_Page_Template