This document outlines the tax considerations for investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on the implications of the Offshore Fund Rules for UK residents and non-residents. It discusses the tax treatment of income and capital gains for UK resident individuals and companies, as well as non-UK resident investors. The document also addresses the potential inheritance tax implications for limited partnership interests in the UK.
doj/DataSet10/EFTA01394258.pdf
{"title":"Cedar Legal: ERISA and Tax Considerations","document_type":"legal","key_locations":["UK"],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital","Cedar Legal"],"reference_numbers":["DB-SDNY-0100256","SDNY_GM_00246440","EFTA01394258"]}