The document outlines tax considerations and legal implications for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It discusses the potential tax liabilities and adjustments that may arise from audits, the treatment of dividends and passive foreign investment companies (PFICs), and the implications of investing in controlled foreign corporations (CFCs). It also covers the restrictions on the deductibility of expenses and other losses for U.S. investors.
doj/DataSet10/EFTA01394650.pdf
{"key_people":["Lawrence Hirsch"],"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0100684","SDNY_GM_00246868","EFTA01394650"]}