Non-U.S. investors who participate in trade or business operations within the United States are subjected to taxation on their income that is effectively linked to those specific operations, commonly referred to as effectively connected income or ECI. Compliance with U.S. tax laws requires non-U.S. investors engaged in trade or business operations within the United States to fulfill their obligation of filing U.S. tax returns accordingly. The majority of non-U.S. investors strive to evade ECI so as not be mandated to file U.S. federal income tax returns. When a fund is not actively involved in trade or business operations within the United States, non-U.S.investors generally do not face liability for U.S.income taxes on capital gains resulting from the sale of portfolio investments made by said fund. To circumvent ECI, it is imperative for funds not to invest directly into flow-through operating entities unless they employ a blocker structure.