This section of the document discusses legal, ERISA, and tax considerations for investors in the Secondary Opportunities Fund III, LP, particularly focusing on tax implications for non-US investors. It outlines the US federal income tax considerations, including withholding tax rates, effectively connected income (ECI), and potential tax liabilities for non-US investors engaged in US trade or business through the fund. The document also addresses the branch profits tax applicable to non-US corporate investors and the potential for tax treaty exemptions.
documents/EFTA01452019.pdf
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