Under Section 457A of the Internal Revenue Code, if an investment manager of an offshore fund is owed deferred fees that are scheduled to be paid after 2017, the investment manager will be subject to tax on such deferred fees in 2017 even though payment is not received until a later year. If you wish to accelerate the payment date of any such deferrals into 2017, you must amend your deferral election no later than December 31, 2011 in order for such deferred amounts to be paid in 2017.
If you have any questions regarding this email, please contact Dan Murphy (212-574-1210), Jim Cofer (212-574-1688), Ron Cima (212-574-1471) or Peter Pront (212-574-1221) of our Tax Group.
