This document outlines the ERISA and tax considerations for the Glendower Capital Secondary Opportunities Fund IV, LP. It discusses the implications of partnership audit procedures, the ineligibility of U.S. corporations for dividends received deductions, the treatment of passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs), and the restrictions on the deductibility of expenses and losses. The document also covers the potential tax liabilities and reporting requirements for U.S. investors involved with PFICs and CFCs.
documents/vol00010-efta01355238-pdf.pdf
{"title":"Glendower Capital Secondary Opportunities Fund IV, LP","document_type":"legal","document_subtype":"ERISA and Tax Considerations","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"]}