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Revenue Ruling Allows Tax-Deferred Stock Rights for Managers of Offshore Funds
McDermott Will & Emery 
June 23, 2014
"Section 457A of the [Code] generally restricts the ability of offshore funds and other entities domiciled in tax-indifferent jurisdictions to offer tax-advantaged deferred compensation to U.S. persons.... Revenue Ruling 2014-18 ... allows an offshore fund to compensate its managers with stock rights that will only be subject to U.S. tax upon exercise, so long as the stock right is exempt from Section 409A and the manager has the same redemption rights with respect to acquired shares as other shareholders of the hedge fund."
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