The document outlines the terms and tax considerations for the Onshore and Offshore Feeder Funds associated with the Master Fund. The Onshore Feeder Fund is treated as a partnership for U.S. federal income tax purposes, while the Offshore Feeder Fund elects to be treated as a foreign corporation. The document highlights potential tax implications for investors, especially U.S. tax-exempt investors, and advises them to consider the Offshore Feeder Fund to avoid UBTI.
doj/DataSet10/EFTA01451513.pdf
{"document_type":"legal","document_subtype":"Feeder LP Agreement","key_organizations":["Southern Financial LLC"],"reference_numbers":["DB-SDNY-0108156","SDNY_GM_00254340","EFTA01451513"]}