 Ineligible 457 plans are made available because nonprofit organizations are not allowed to have another kind of nonqualified deferred-compensation plan.Generally, these deferred amounts would be currently taxable under section 83 of the code, unless the employee faces a "substantial risk of forfeiture", which has been clarified by the IRS to mean that in addition to the money remaining available to general creditors of the organization or subject to not vesting, and if the employee does not stay with the employer for the full vesting period.When the risk of forfeiture is gone, the value of the property given to the employee ceases to be deferred from taxation and is included in current ordinary gross income.