The document discusses the tax implications for the Access Fund and its Limited Partners, including the treatment of debt restructuring as a taxable event, potential investments in derivatives, and the impact of investing in entities treated as partnerships for U.S. federal income tax purposes. It also covers the implications of investing in Passive Foreign Investment Companies (PFICs) and the potential tax consequences for U.S. Tax-Exempt Investors due to Unrelated Business Taxable Income (UBTI).
doj/DataSet10/EFTA01391379.pdf
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