This section of the document discusses the legal, ERISA, and tax considerations for the Glendower Capital Secondary Opportunities Fund IV, LP. It outlines the implications of partnership audit procedures, the treatment of dividends and passive foreign investment companies (PFICs), controlled foreign corporations (CFCs), and certain transactions that may generate taxable income without cash distribution. It also addresses restrictions on the deductibility of expenses and other losses for U.S. federal income tax purposes.
doj/DataSet10/EFTA01391453.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"]}