Hedge Fund managers previously had an unprecedented ability to defer their carried interest in the offshore hedge funds that they manage. IRC Sec. 409A put an end to those deferrals and required hedge fund managers to repatriate their offshore carried interest no later than December 31, 2017. On a personal level, I was aware of small hedge fund managers with $30-50 million of deferred carried interest. On the flip side of things, I was aware of large fund managers with $750 million to $1 billion...By: Gerald Nowotny.