Executive Deferred Compensation

Is there any creative way to establish an executive deferred compensation plan for a partnership.  I totally understand the flow-through issue but this firm is adamant that there has got to be a way to create such a program for partners that are retiring and getting a return of their capital contributions (all seven figure distributions).  If they are recategorized as income partners instead of equity partners, would that make a difference or would the capital distributions still be treated as K-1 income?  Any thoughts are welcome!!

Unfunded deferred compensation plans are set up all the time for partners in partnerships, note for example many of the large CPA firms which operate as partnerships and have very robust non-qualified "retirement" plans for partners.

What is it your client is trying to accomplish that you feel is problematic just because it's a partnership?

Absent unusual circumstances (maybe), distributions of capital accounts to retiring partners are, of course, nontaxable.

What types of nonqualified plans are set up for partners?  Can a partner defer his/her annual distribution of income to a nonqualified plan?  Wouldn't the deferred amount just flow back to him/her anyway?