nonqualified deferred compensation plan
(2) Treatment of certain nonqualified deferred compensation plans (A) In general Any amount deferred under a nonqualified deferred compensation plan shall be taken into account for purposes of this chapter as of the later of— (i) when the services are performed, or (ii) when there is no substantial risk of forfeiture of the rights to such amount. The preceding sentence shall not apply to any excess parachute payment (as defined in section 280G(b) ) or to any specified stock compensation (as defined in section 4985) on which tax is imposed by section 4985. (B) Taxed only once Any amount taken into account as wages by reason of subparagraph (A) (and the income attributable thereto) shall not thereafter be treated as wages for purposes of this chapter. (C) Nonqualified deferred compensation plan For purposes of this paragraph, the term “nonqualified deferred compensation plan” means any plan or other arrangement for deferral of compensation other than a plan described in subsection (a)(5).