This section outlines the tax and legal considerations for the Glendower Capital Secondary Opportunities Fund IV, LP, including partnership audit procedures, tax liabilities, and investment in foreign corporations. It discusses the implications of adjustments at the fund level, the Push-Out Election, and the treatment of passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs). It also covers the restrictions on deductibility of expenses and other losses for U.S. investors.
doj/DataSet10/EFTA01393679.pdf
{"title":"Glendower Capital Secondary Opportunities Fund IV, LP - Section 9: Certen Legal, ERISA and Tax Considerations","document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"]}