457(f) - Payment Subsequent to Vesting

[jpod]

Is there still the understanding that there is no Federal income tax withholding simply do to the vesting and consequent income inclusion of deferred compensation under Section 457(f) where there is nothing being paid until later? Is there a more recent statement from the IRS on this than the 1999 TAM, either another TAM or PLR or even in a speech?

[Carol V. Calhoun]

I've heard informally that IRS has not retreated from that position, but I haven't seen anything formal.