ult in foreign currency gain or loss realized by the Fund and will be included in the U.S. Partners’ distributive shares of Fund profits or losses as U.S.-source ordinary income or loss rather than capital gain or loss. 78 CONTROL NUMBER 257 - CONFIDENTIAL HOUSE_OVERSIGHT_024089 --- PAGE BREAK --- U.S. Rep

er new law, FIRPTA does not apply to the foreign pension fund, so the capital gain on sale of the stock is exempt from U.S. income tax. Note that the U.S.-source interest paid to the foreign shareholder could be subject to U.S. withholding tax under the regular rules of the Code, but if the pension fund is org