The document discusses the tax implications and considerations for Limited Partners in the sale of interests in the Access Fund, including capital gains, tax basis adjustments, and limitations on the deductibility of interest expenses. It also outlines the conditions under which the Access Fund would terminate for U.S. federal income tax purposes and the potential elections under Sections 754 and 743 of the Code.
doj/DataSet10/EFTA01393611.pdf
{"document_type":"financial","document_subtype":"investment document","key_organizations":["Bright Group","Access Fund"],"reference_numbers":["Section 754","Section 743","Section 163(d)"]}