This document outlines the tax implications for U.S. persons and tax-exempt investors involved with the Georgetown University Endowment's Access Fund, particularly in relation to Controlled Foreign Corporations (CFCs) and foreign currency transactions. It discusses the tax responsibilities of Limited Partners who are U.S. persons, including the inclusion of certain earnings in gross income 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 other income-generating activities.
doj/DataSet10/EFTA01389305.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Georgetown University Endowment","Access Fund"],"reference_numbers":["DB-SDNY-0093660","SDNY_GM_00239844","EFTA01389305"]}