This document is a section from the Glendower Capital Secondary Opportunities Fund IV, LP's Private Placement Memorandum, discussing ERISA and tax considerations for investors. It covers topics such as the deductibility of expenses, qualified business income deductions, and tax implications for ERISA plans, tax-exempt limited partners, and non-U.S. investors. The document outlines potential tax liabilities, including unrelated business taxable income (UBTI) and effectively connected income (ECI), and advises non-U.S. investors to consult with tax advisers.
doj/DataSet10/EFTA01389832.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital","ERISA"],"reference_numbers":["DB-SDNY-0094198","SDNY_GM_00240382","EFTA01389832"]}