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, including withholding taxes and branch profits tax, and the reporting requirements for U.S. investors.
doj/DataSet10/EFTA01391173.pdf
{"document_type":"legal","document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital","Third Lake Capital"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}