This document outlines the tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on the treatment of effectively connected income (ECI) and the implications of investing in U.S. real property holding corporations. It discusses the tax rates applicable to non-U.S. investors, potential withholding taxes, and the branch profits tax. The document also highlights certain reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for transactions to be classified as reportable under U.S. federal tax rules.
doj/DataSet10/EFTA01393399.pdf
{"document_type":"legal","document_subtype":"Tax Considerations","key_organizations":["Glendower Capital","Aspen Grove Capital, LLC"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}