This document outlines the tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund W. LP, particularly focusing on the implications of engaging in U.S. trade or business through an Operating Partnership. It discusses the treatment of effectively connected income (ECI), withholding tax rates, branch profits tax, and potential use of a blocker structure for non-U.S. investors. It also covers reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the implications of reportable transactions.
doj/DataSet10/EFTA01394255.pdf
{"title":"Glendower Capital Secondary Opportunities Fund W. LP","document_type":"legal","key_locations":["U.S."],"document_subtype":"ERISA and Tax Considerations","key_organizations":["Glendower Capital Secondary Opportunities Fund W. LP"]}