Despite the fact that taxable investors would prefer to defer the real
ization of capital gains indefinitely, most open-end mutual funds regu
larly realize and distribute a large portion of their gains. We presen
t a model in which unrealized gains in the fund's portfolio increase e
xpected future taxable distributions, and thus increase the present va
lue of a new investor's tax liability. In equilibrium, managers intere
sted in attracting new investors pass through taxable capital gains to
reduce the overhang of unrealized gains. This model contains a number
of empirical predictions that are consistent with data on actual fund
overhangs. (C) 1998 Elsevier Science S.A. All rights reserved.