The document discusses the tax implications for U.S. persons and entities investing in controlled foreign corporations (CFCs) through the Access Fund. It outlines the rules for U.S. shareholders of CFCs, including the need to include certain earnings in gross income and the treatment of gains as dividend income. It also covers the impact of the 2017 Tax Legislation on deferred earnings and the treatment of foreign currency gains or losses. Additionally, it addresses the potential for unrelated business taxable income (UBTI) for U.S. Tax-Exempt Investors due to leverage and other income-generating activities by the Access Fund.
doj/DataSet10/EFTA01393865.pdf
{"document_type":"financial","document_subtype":"tax document","key_organizations":["Forrestal Capital LLC","Access Fund"],"reference_numbers":["DB-SDNY-0099702","SDNY_GM_00245886","EFTA01393865"]}