Deadline For Grandfathered Deferrals Payable After 2017

We are writing to remind you of an approaching deadline for accelerating certain previously grandfathered deferrals otherwise payable in taxable years beginning on or after January 1, 2018.

Section 457A of the Internal Revenue Code effectively prohibits the offshore deferral of compensation paid to managers of hedge funds and may affect a range of other deferral plans involving tax-indifferent partners. Deferrals attributable to pre-January 1, 2009 services are exempt from Section 457A under a transition rule but are required by that rule to be included in the service provider's income by the last taxable year beginning before January 1, 2018 (or, if later, by the first taxable year in which the right to payment vests) (the "required inclusion year").