"[T]he IRS did not rule on any aspect of the program other than the impact of the contingent benefit rule. Many additional factors should be considered in deciding whether to adopt such a program, some of which are discussed in this document.... While variance from [the specific design described in PLR 201833012] may be permissible, employers are strongly encouraged to consult with outside counsel to the extent material changes from [this design] will be made."  MORE >>