As part of the Emergency Economic Stabilization Act of 2008 (H.R. 1424) (the "Act"), Congress added new § 457A to the Internal Revenue Code of 1986, as amended (the "Code"). Section 457A was prompted by a perceived need to curb deferral of income inclusion for popular fee arrangements currently used by offshore hedge funds. When a service recipient is not tax indifferent, a tension typically will exist between a service provider's interest in deferring income and a service recipient's need for a current deduction for that income payment....
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