This document outlines the tax considerations and legal implications for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund W. LP, particularly focusing on the treatment of income as effectively connected income (ECI) and the associated tax rates. It also discusses the potential use of a blocker structure for non-U.S. investors and the implications of investing in U.S. real property holding corporations. Additionally, it highlights the reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for transactions to be classified as reportable under U.S. federal tax rules.
doj/DataSet10/EFTA01392475.pdf
{"key_people":["Patrick Gerschel"],"document_type":"legal","key_locations":["U.S."],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund W. LP"]}