The document outlines tax considerations and legal implications for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It discusses the potential tax liabilities and adjustments at the fund level, the implications of partnership audit procedures, and the treatment of investments in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs). It also covers the restrictions on the deductibility of expenses and other losses for U.S. investors.
doj/DataSet10/EFTA01386679.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0088466","SDNY_GM_00234650","EFTA01386679"]}