This document is a section from the Confidential Private Placement Memorandum for the Glendower Capital Secondary Opportunities Fund IV, LP. It discusses legal, ERISA, and tax considerations for investors, including organizational expenses, investment interest expense limitations, qualified business income deductions, and tax implications for ERISA plans, tax-exempt limited partners, and non-U.S. investors. The document outlines potential tax liabilities such as unrelated business taxable income (UBTI) and effectively connected income (ECI) for non-U.S. investors.
doj/DataSet10/EFTA01383070.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital","Southern Financial LLC"],"reference_numbers":["DB-SDNY-0082681","SDNY_GM_00228865","EFTA01383070"]}