The document discusses the tax implications and conditions related to the sale of interests in Southern Financial LLC's Access Fund. It covers capital gains, tax basis adjustments, and limitations on the deductibility of interest expenses for non-corporate taxpayers. The document also outlines the conditions under which the Access Fund would terminate for U.S. federal income tax purposes and the potential elections under Section 754 of the Code.
doj/DataSet10/EFTA01386597.pdf
{"document_type":"financial","document_subtype":"investment document","key_organizations":["Southern Financial LLC","Access Fund"],"reference_numbers":["DB-SDNY-0088359","SDNY_GM_00234543","EFTA01386597"]}