This document outlines the tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund IV, LP, particularly focusing on the treatment of effectively connected income (ECI) and the implications of investing in U.S. real property holding corporations. It also discusses potential tax liabilities, withholding requirements, and reporting obligations for both U.S. and non-U.S. investors.
doj/DataSet10/EFTA01393681.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}