The IRS Dec. 5 released proposed rules (REG-148326-05) on the calculation of amounts includible in income under tax code Section 409A and the additional taxes imposed by that section with respect to service providers participating in certain nonqualified DCPs.

Text of REG-148326-05 is available at http://www.federalregister.gov/OFRUpload/O...08-28894_PI.pdf.