Single-Employee Tax-Exempt Organization 457 Plan

[Plan Doc]

Can a tax-exempt organization whose executive director is the only employee establish a 457(b) or a 457(f) plan for this individual?

I'm not sure it satisfies the "top-hat" requirements since effectively 100% of the organization's workforce will be participating. 

[Peter Gulia]

Among many ambiguities:

Is the worker is a management employee.

Is the worker “highly compensated”?

Might an ostensible income deferral be unreal because the organization and its employee did not truly agree that the deferred compensation is unfunded?

Which person bears which risks?

This is not advice to anyone.