The document discusses the tax implications and conditions related to the sale of interests in the Access Fund by Limited Partners. It covers capital gains, tax basis adjustments, and limitations on the deductibility of interest expenses. 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 and Section 743 of the Code.
doj/DataSet10/EFTA01389726.pdf
{"key_people":["General Partner","Limited Partner"],"document_type":"financial","document_subtype":"investment agreement","key_organizations":["Access Fund"],"reference_numbers":["GLDUS132","DB-SDNY-0094090","SDNY_GM_00240274","EFTA01389726"]}