This document outlines the tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on the treatment of income as effectively connected income (ECI) and the implications of investing in U.S. real property holding corporations. It also discusses potential tax liabilities, including withholding taxes and branch profits tax, and the possibility of using a 'blocker structure' for non-U.S. investors. Additionally, it highlights reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for transactions to be classified as reportable to the IRS.
documents/vol00010-efta01364829-pdf.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP","Southern Financial LLC"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}