Discussion on the tax implications of restructuring debt obligations and investments by the Access Fund, including potential taxable events, investment in derivatives, and implications for U.S. Tax-Exempt Investors. It also covers the potential classification of investments as Passive Foreign Investment Companies (PFIC) and the associated tax consequences.
doj/DataSet10/EFTA01394556.pdf
{"key_people":["Lawrence Hirsch"],"document_type":"correspondence","document_subtype":"memo","key_organizations":["Access Fund"],"reference_numbers":["DB-SDNY-0100580","SDNY_GM_00246764","EFTA01394556"]}