This document discusses the tax implications for U.S. persons and U.S. Tax-Exempt Investors involved with Controlled Foreign Corporations (CFCs) and the Access Fund. It outlines the rules for U.S. Shareholders of CFCs, including the need to include certain earnings in gross income and the treatment of gains as dividend income. It also covers the impact of the 2017 Tax Legislation on deferred earnings and the tax treatment of foreign currency gains or losses. Additionally, it warns U.S. Tax-Exempt Investors about potential Unrelated Business Taxable Income (UBTI) due to leverage and other income-generating activities by the Access Fund.
documents/vol00010-efta01354642-pdf.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Access Fund"],"reference_numbers":["GLDUS125"]}