Faegre Drinker·TAX
Treasury and IRS flag tax-aware fund strategies as problematic
IRS and Treasury guidance signals that tax-aware fund structuring may be challenged and expressly reserves retroactive authority, putting completed transactions — including securities lending and gain-deferral techniques — back in play.
irs-guidancetax-aware-investingsection-7805retroactive-authorityfund-taxationtreasury-department
Read the original firm alert → Wednesday, October 7, 2026