This document outlines the tax and legal considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on the implications of investing in U.S. trade or business through an Operating Partnership. It discusses the treatment of effectively connected income (ECI) for non-U.S. investors, applicable tax rates, potential withholding taxes, and the branch profits tax. The document also covers the possibility of using a 'blocker' structure for non-U.S. investors and the implications of investing in U.S. real property holding corporations. Additionally, it highlights certain reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for transactions to be classified as 'reportable transactions' under U.S. federal tax rules.
doj/DataSet10/EFTA01389407.pdf
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