The document discusses the tax implications of restructuring a debt obligation acquired by the Access Fund, potential investments in derivatives, partnerships, and passive foreign investment companies (PFICs). It highlights the tax consequences for Limited Partners and U.S. Tax-Exempt Investors, including the possibility of UBTI and increased tax liability under the PFIC regime.
doj/DataSet10/EFTA01391097.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Access Fund","Third Lake Capital"],"reference_numbers":["GLDUS139","DB-SDNY-0095836","SDNY_GM_00242020","EFTA01391097"]}