This document is a section from a legal memorandum related to Glendower Capital Secondary Opportunities Fund IV, LP. It discusses ERISA and tax considerations for investors, including organizational expenses, qualified business income deductions, and tax implications for ERISA plans, tax-exempt limited partners, and non-U.S. investors. The document outlines potential tax liabilities such as unrelated business taxable income (UBTI) and effectively connected income (ECI) for different types of investors.
doj/DataSet10/EFTA01393398.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital","Aspen Grove Capital, LLC"],"reference_numbers":["DB-SDNY-0098941","SDNY_GM_00245125","EFTA01393398"]}