The document discusses the tax implications of restructuring debt obligations and investments by the Access Fund, including potential taxable events, investment in derivatives, and partnerships. It highlights the complexities of U.S. federal income tax consequences for Limited Partners, especially concerning Passive Foreign Investment Companies (PFICs) and U.S. Tax-Exempt Investors. The document advises prospective investors to consult tax advisors regarding these rules.
documents/vol00010-efta01364724-pdf.pdf
{"document_type":"financial","document_subtype":"tax advisory","key_organizations":["Access Fund","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0055272","SDNY_GM_00201456","EFTA01364724"]}