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, the impact of the 2017 Tax Legislation on deferred earnings, and the treatment of foreign currency gains or losses. It also highlights the potential for Unrelated Business Taxable Income (UBTI) for U.S. Tax-Exempt Investors due to leverage and certain income types.
doj/DataSet10/EFTA01393613.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Access Fund"]}