This section of the document discusses the tax and legal considerations for the Glendower Capital Secondary Opportunities Fund IV, LP, particularly in relation to ERISA and tax implications. It covers the procedures for handling tax adjustments at the fund level, the implications of the Push-Out Election, and the treatment of dividends and investments in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs). It also addresses the tax treatment of certain transactions and restrictions on the deductibility of expenses and losses.
doj/DataSet10/EFTA01389405.pdf
{}