Church NQDC Taxable on Vesting?

A church, which is recognized as a 501(c)(3) organization, sponsors a 403(b) plan and wants to establish a nonqualified deferred compensation plan for its senior pastor.  The NQDC plan will be designed to comply with Internal Revenue Code Section 409A.

Are contributions to the church's NQDC plan taxable upon vesting, as typically occurs with non-church tax-exempt organization NQDC plans?

From what I've read in multiple places, IRC Section 457 does not apply to churches. Since it's 457(f) that makes amounts taxable upon vesting, I don't think you have that issue. This is a nice article albeit 20+ years old. 

https://www.churchlawandtax.com/stay-legal/clergy-law/nonqualified-church-retirement-plans-should-be-legally-reviewed/

Thanks, CuseFan; the pastor will be pleased with this earthly offering!

The webpage has an error in its citation of the ruling.

IRS Letter Ruling 2001-10-005 (issued Nov. 14, 2000, released Mar. 9, 2001) http://www.legalbitstream.com/scripts/isyswebext.dll?op=get&uri=/isysquery/irl781f/1/doc.

The pastor would have gross income when she receives the deferred compensation.