US tax tweaks could upend SWFs' US investments
US IRS proposals to tighten Section 892 could strip tax-exempt status from sovereign wealth funds and some public pensions that engage in US investments, by redefining when debt purchases and other activities count as 'commercial activity' and by widening 'effective control' tests. The changes would affect private credit, private equity co-investments and real assets, potentially costing SWFs billions in avoided taxes and prompting restructurings or shifts to more passive strategies; final rules are not settled yet, with comments due Feb 13.