This section of the memorandum discusses the tax and ERISA considerations for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It covers the deductibility of expenses, limitations on business interest deductions, and the implications for ERISA plans and non-U.S. investors. The document highlights potential UBTI generation and the tax obligations for non-U.S. investors, including withholding tax and effectively connected income.
doj/DataSet10/EFTA01394254.pdf
{"title":"Glendower Capital Secondary Opportunities Fund IV, LP - ERISA and Tax Considerations","key_people":["Manager","General Partner"],"document_type":"legal","key_locations":["United States"],"document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0100252","SDNY_GM_00246436","EFTA01394254"]}