This section of the document discusses the legal, ERISA, and tax considerations for the Glendower Capital Secondary Opportunities Fund IV, LP. It covers the implications of partnership audit procedures, the treatment of dividends and investments in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs), and the restrictions on the deductibility of expenses and losses for U.S. federal income tax purposes.
doj/DataSet10/EFTA01391172.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital","Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0095940","SDNY_GM_00242124","EFTA01391172"]}