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Sovereign wealth funds (SWFs) are governmental investment vehicles, often funded with foreign exchange assets, and managed separately from the official reserves of a monetary authority.¹ They have recently attracted the attention of Congress and the imagination of the public press.² This attraction may be the result of several factors, including an increase in commodity prices, growth in the size and public nature of SWF investments, and the recent U.S. credit crunch. In any event, Senators Baucus and Grassley of the Committee on Finance have requested the Joint Committee on Taxation "[to] describe and [to] analyze the history, current rules, and policy underpinnings of the U.S. tax rules applicable to U.S. investment by foreign governments, including investments made by Sovereign Wealth Funds."³ They indicated that "we ought to ... have a clear understanding of the U.S....

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