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IRS Revenue Ruling Permits Deferred Comp Opportunities for U.S. Fund Managers of Offshore Hedge Funds
Haynes Boone via Lexology; registration required Link to more items from this source
July 9, 2014

"The Ruling provides U.S. hedge fund managers with flexibility in structuring their compensation arrangements with offshore vehicles. For example, Options and SARs can be structured to lock a fund manager's incentive compensation into the value of the fund itself for a fixed number of years or upon the occurrence of certain events (e.g., the exiting of the investor) by agreeing in advance when the Options or SARs will be exercisable. By effectively allowing multi-year fee deferrals, the Ruling permits investors to better align their interests with the fund managers, without investors asking for a clawback of fees."  MORE >>

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