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regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
regarded for ERISA controlled group liability purposes as engaging in a "trade or business" (the "2013 Sun Capital Case"). Further, in March 2016, the U.S. District Court for the District of Massachusetts held that affiliated private equity funds investing in the same portfolio company may form a "partnership-in- fac
es for three years and may carry forward such losses for five years; non-corporate taxpayers may carry forward unused capital losses indefinitely. Tax Treatment of Investments. In general and except as discussed below, the Access Fund expects that its gains will be treated as capital gain for U.S. federal income tax purpo
Entities connected to both United States District Court and Tax Treatment of Investments

United States
LOCATION
U.S. Virgin Islands
LOCATIONthe District of Massachusetts
LOCATIONthe First Circuit
ORGANIZATIONInvestment Concentration
ORGANIZATIONGlendower
LOCATIONthe District of Columbia
LOCATION
Eric Holder
PERSONCalder
ORGANIZATION
United Kingdom
LOCATION
Puerto Rico
LOCATION
Cyprus
LOCATION
Denmark
LOCATION
Lithuania
LOCATIONCity of New York
LOCATION
Ireland
LOCATION
Fidelity
ORGANIZATION
Slovakia
LOCATION
Belgium
LOCATION
Liechtenstein
LOCATION