The document discusses tax implications for U.S. and non-U.S. investors in the Onshore Feeder Fund, including the potential for unrelated business taxable income (UBTI) for tax-exempt investors and the complexities of making a section 754 election under the U.S. tax code.
doj/DataSet10/EFTA01451523.pdf
{"document_type":"financial","document_subtype":"investment fund tax information","key_organizations":["Southern Financial LLC","Onshore Feeder Fund","Offshore Feeder Fund"],"reference_numbers":["DB-SDNY-0108172","SDNY_GM_00254356","EFTA01451523"]}