This document outlines the legal and 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 discusses the tax rates applicable to non-U.S. investors, potential withholding taxes, and the branch profits tax. The document also highlights reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for certain transactions to be classified as reportable under U.S. federal tax rules.
documents/EFTA01390867.pdf
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