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IRS – Possible Offshore Deferrals for Hedge Fund Managers by Proskauer Rose

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The Internal Revenue Service (the "IRS") has issued Revenue Ruling 2014-18 (the "Ruling")[1], which generally confirms that a stock-settled stock option or stock appreciation right that is granted with an exercise/base price of no less than the fair market value of the underlying stock on the date of grant will…

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