The document discusses the tax considerations and legal implications for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It covers topics such as partnership audit procedures, the impact of adjustments on partners, the Push-Out Election, and the treatment of non-U.S. corporations as passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs). It also addresses the restrictions on the deductibility of expenses and other losses for U.S. federal income tax purposes.
documents/vol00010-efta01354742-pdf.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0039340","SDNY_GM_00185524","EFTA01354742"]}