The document discusses the tax implications for U.S. persons investing in controlled foreign corporations (CFCs) through the Access Fund. It outlines the rules for U.S. shareholders of CFCs, including the requirement to include certain earnings in gross income and the treatment of gains as dividend income. The document also covers the impact of the 2017 Tax Legislation on deferred earnings and the tax treatment of foreign currency gains or losses. Additionally, it addresses the potential for unrelated business taxable income (UBTI) for U.S. Tax-Exempt Investors due to leverage and other income-generating activities by the Access Fund.
documents/vol00010-efta01364725-pdf.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Southern Financial LLC","Access Fund"],"reference_numbers":["DB-SDNY-0055273","SDNY_GM_00201457","EFTA01364725"]}