Yes, some older drives may not be compatible. I figured my current Samsung 840 would be compatible so I went ahead and turned on TRIM.
Mind you my older Kingston V+100 drive gets no significant improvement with TRIM anyway. This drive has a controller that was used in Macs before Apple enabled TRIM even for its own SSDs. The Toshiba controller has super hardcore aggressive garbage collection. Here's the review of that drive from AT's ex-boss, Anand:
http://www.anandtech.com/show/4010/kingston-ssdnow-v-plus-100-review
Now look at Kingston's SSDNow V+100, both before fragmentation and after:
There's hardly any difference. Actually the best way to see this in work is to look at power draw when firing random write requests all over the drive. The SSDNow V+100 has wild swings in power consumption during our random write test ranging from 1.25W to 3.40W. The swings would happen several times in a window of a couple of seconds. The V+100 is aggressively tries to reorganize writes and recycle bad blocks, more aggressively than we've seen from any other SSD.
The benefit of this is you get peak performance out of the drive regardless of how much you use it, which is perfect for an OS without TRIM support - ahem, OS X. Now you can see why Apple chose this controller.
That said, TRIM didn't cause any problems with it when I enabled it in the past on this drive with TRIM Enabler.