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

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