This document is a section from the Glendower Capital Secondary Opportunities Fund IV, LP's Confidential Private Placement Memorandum. It discusses ERISA and tax considerations for investors, including organizational expenses, investment interest expense limitations, 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/EFTA01394651.pdf
{"key_people":["Lawrence Hirsch"],"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0100685","SDNY_GM_00246869","EFTA01394651"]}