This document is a section from the Confidential Private Placement Memorandum for Glendower Capital Secondary Opportunities Fund IV, LP. It discusses the tax implications for non-U.S. investors in the fund, particularly regarding effectively connected income (ECI) and U.S. real property holding corporations. It outlines the tax rates applicable to non-U.S. investors, potential withholding taxes, and the branch profits tax. The document also covers reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the implications of reportable transactions under U.S. federal tax rules.
documents/vol00010-efta01354744-pdf.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}