4 pages. Excerpt: Section 457A will have a substantial impact on many offshore hedge funds organized in certain tax havens (e.g., Bermuda, Hong Kong, and the Cayman Islands). Management and incentive fees paid by such funds will need to be either (i) subject to a 'substantial risk of forfeiture' under Section 457A, or (ii) converted to a general partner carried interest in a 'master feeder' type of arrangement. In addition, management companies organized in tax havens may no longer be able to offer efficient deferred compensation to their employees who are U.S. taxpayers.  MORE >>