Which one of the following is a correct statement of a tax consequence of an off-shore rabbi trust? A) Under Section 409A, the employee is taxed immediately on all deferrals to the plan and interest dating from each deferral, and is assessed a 20% penalty on the resulting taxable income. B) Under Section 409A, the employer is taxed immediately on all deferrals to the plan and interest dating from each deferral. C) The employer can be discriminatory but must offer the plan to all key employees. D) The employer recognizes a deduction when it makes contributions to the off-shore trust