This document discusses the tax implications for U.S. persons and entities investing in 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 complexities of CFC and deemed repatriation rules. Additionally, it addresses foreign currency gains or losses and the potential for unrelated business taxable income (UBTI) for U.S. Tax-Exempt Investors.
documents/vol00010-efta01354211-pdf.pdf
{"key_people":["Henry Nicholas"],"document_type":"financial","document_subtype":"tax document","key_organizations":["Access Fund"],"reference_numbers":["GLDUS143"]}