The highest-paid non-management developer that I know of had a base salary of $185k. That may or may not be the ceiling, but there certainly is some salary ceiling.
Ways to break through that salary ceiling:
1. Direct reports. If you manage even one person, then base salaries quickly go into the $200 and $300 thousands.
2. Highly specialized technical knowledge. For example, I know SAP implementers with base salaries in the $200s. They're not really "developers" anymore however.
3. Highly specialized domain knowledge. For example, a developer with enough knowledge of organic chemistry can make a $200k+ base at a pharmaceutical company.
4. Work for yourself. A fully-loaded consultant will easily make mid-$200k and I know several people who are consistently grossing in the low $300ks.
Note the importance of base salary. Bonuses and profit sharing can easily add 50% or more to your earnings. For example, the $100k developer at CoStar is probably taking home more than the $175k developer at AOL.