This section of the memorandum discusses legal, ERISA, and tax considerations for investors in the Secondary Opportunities Fund III, LP. It covers the potential use of a 'blocker' structure for non-US investors, implications of investing in US real property holding corporations, and various US tax reporting requirements for investors. It also addresses the Foreign Account Tax Compliance Act (FATCA) and its implications for the fund and its investors, including potential withholding taxes and reporting obligations under bilateral agreements with the UK and Cayman Islands.
documents/EFTA01452020.pdf
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