The document outlines legal and tax considerations for investors in the Secondary Opportunities Fund III, LP. It discusses the ineligibility of US corporate investors for dividends received deductions from non-US corporations, the tax implications of investing in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs), and the restrictions on deductibility of expenses and losses. It also addresses the potential for generating unrelated business taxable income (UBTI) for ERISA plans and other tax-exempt limited partners.
documents/EFTA01452018.pdf
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