This document outlines the tax implications for U.S. persons and U.S. Tax-Exempt Investors involved with controlled foreign corporations (CFCs) and the Access Fund. It discusses the rules for U.S. shareholders of CFCs, including the inclusion of 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 highlights 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.
doj/DataSet10/EFTA01382997.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Southern Financial LLC","Access Fund"],"reference_numbers":["DB-SDNY-0082577","SDNY_GM_00228761","EFTA01382997"]}