This document outlines the tax considerations for Glendower Capital Secondary Opportunities Fund IV, LP, including partnership audit procedures, treatment of dividends, investments in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs), and restrictions on deductibility of expenses and losses. It discusses the implications of adjustments at the fund level, the Push-Out Election, and the impact on U.S. investors, including potential tax liabilities and reporting requirements.
doj/DataSet10/EFTA01389831.pdf
{"title":"Glendower Capital Secondary Opportunities Fund IV, LP - ERISA and Tax Considerations","document_date":"2018","document_type":"legal","document_subtype":"tax considerations","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0094197","SDNY_GM_00240381","EFTA01389831"]}