The document discusses the tax implications and limitations for investors in the Onshore Feeder Fund, including treatment of capital gains and losses, limitations on deductions, and considerations for investments in non-U.S. entities classified as PFICs or CFCs.
doj/DataSet10/EFTA01451522.pdf
{"document_type":"financial","document_subtype":"investment memorandum","key_organizations":["Onshore Feeder Fund","Master Fund","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0108171","SDNY_GM_00254355","EFTA01451522"]}