  We show that the off-shell N=3 action of N=4 super Yang-Mills can be written
as a holomorphic Chern-Simons action whose Dolbeault operator is constructed
from a complex-real (CR) structure of harmonic space. We also show that the
local space-time operators can be written as a Penrose transform on the coset
SU(3)/(U(1) \times U(1)). We observe a strong similarity to ambitwistor space
constructions.
