This document provides a summary of certain U.S. federal income tax considerations related to an investment in the Access Fund, based on the Internal Revenue Code, U.S. Treasury Regulations, and judicial decisions as of the date of the memorandum. It highlights that the IRS may take different positions and that no ruling or opinion from the IRS or counsel has been obtained. The discussion is limited to U.S. persons and does not cover all possible tax considerations, especially for non-U.S. persons or tax-exempt entities. It assumes that Limited Partners will provide necessary certifications to minimize withholding and will hold interests as capital assets.
doj/DataSet10/EFTA01389298.pdf
{"document_type":"financial","key_locations":["United States","District of Columbia"],"document_subtype":"tax considerations","key_organizations":["Georgetown University Endowment","Access Fund","IRS"],"reference_numbers":["DB-SDNY-0093653","SDNY_GM_00239837","EFTA01389298"]}