Who is it deductible to? the employer or employee?
The deduction in option B is the employer's. With a qualified plan the employer deducts its contribution in the year it is made, even though the employee pays no tax until the money is distributed; that matching of a current deduction with deferred income is the main tax advantage of qualification. With a nonqualified deferred compensation arrangement the employer's deduction is postponed until the employee actually receives the benefit and reports it as income. D is wrong because qualified plan benefits are not tax free: distributions from pre-tax contributions and earnings are taxed as ordinary income when received, just like nonqualified benefits.