In CCA 201501013, the IRS Office of Chief Counsel considered whether a fund manager’s lending and stock distribution activities conducted as an agent on behalf of a fund caused the fund to be engaged in a US trade or business.  The Office of Chief Counsel concluded that (1) the nature and extent of the lending and underwriting activities caused the fund to be engaged in a trade or business within the United States; (2) the fund’s lending and underwriting did not constitute “trading in stocks or securities” for purposes of the trading safe harbors under Section 864(b)(2)(A)(i); and (3) even if the fund’s lending and underwriting had constituted “trading in stocks or securities,” the fund would not have qualified for the safe harbors.