This document is a section from the Glendower Capital Secondary Opportunities Fund IV, LP's Confidential Private Placement Memorandum. It discusses legal, ERISA, and tax considerations for investors, including organizational expenses, qualified business income deductions, and implications for ERISA plans and non-U.S. investors. The document outlines potential tax liabilities and considerations for different types of investors, including non-corporate, tax-exempt, and non-U.S. investors, and mentions the possibility of generating unrelated business taxable income (UBTI) through certain investments.
documents/vol00010-efta01353904-pdf.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital","Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0038477","SDNY_GM_00184661","EFTA01353904"]}