This document discusses the tax implications for U.S. persons investing in Controlled Foreign Corporations (CFCs) through the Access Fund. It outlines the responsibilities of U.S. Limited Partners in terms of including certain earnings and profits in their gross income, and the potential tax consequences under Sections 1248 and 751 of the Code. The document also covers the impact of the 2017 Tax Legislation on deferred earnings and the treatment of foreign currency gains or losses. Additionally, it addresses the tax implications for U.S. Tax-Exempt Investors, particularly regarding Unrelated Business Taxable Income (UBTI).
doj/DataSet10/EFTA01392381.pdf
{"key_people":["Patrick Gerschel"],"document_type":"financial","document_subtype":"tax document","key_organizations":["Access Fund"],"reference_numbers":["DB-SDNY-0097596","SDNY_GM_00243780","EFTA01392381"]}