This document outlines the ERISA and tax considerations for investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on UK tax implications for both UK and non-UK resident investors. It discusses the treatment of offshore funds, controlled foreign companies, unrealized gains or losses, and the implications for pension funds and other exempt bodies. Additionally, it covers UK taxation of non-UK resident investors, including income and capital gains tax considerations, and inheritance tax implications for limited partnership interests.
doj/DataSet10/EFTA01383073.pdf
{"document_type":"legal","key_locations":["UK"],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0082685","SDNY_GM_00228869","EFTA01383073"]}