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 also discusses potential tax liabilities, including withholding taxes and branch profits tax, and the possibility of using a 'blocker structure' for non-U.S. investors. Additionally, it highlights the reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for transactions to be classified as reportable to the IRS.
doj/DataSet10/EFTA01393929.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital","Forrestal Capital LLC"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}