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Impact of IRC Section 457A on Fund Structures

October 22, 2008


As you are aware, on Oct. 3, 2008, the Emergency Economic Stabilization Act of 2008 (H.R. 1424) was signed into law. The Act adds new Section 457A to the Internal Revenue Code of 1986, as amended, which may significantly affect fees charged by certain investment managers for services provided to offshore funds after Dec. 31, 2008.