• Recent Legislation May Impact Offshore Hedge Fund Deferral Arrangements
  • February 25, 2005 | Authors: Elizabeth Shea Fries; Marian A. Tse; Robert G. Kester
  • Law Firm: Goodwin Procter LLP - Boston Office
  • Congress enacted Section 409A of the Internal Revenue Code as part of the American Jobs Creation Act of 2004 to restrict certain deferred compensation arrangements. The IRS recently issued Notice 2005-1, 2005-2 IRB 274, clarifying certain aspects of the statute, and additional guidance is expected throughout 2005.