This section of the Private Placement Memorandum discusses the ERISA and tax considerations for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It covers the deductibility of organizational expenses, limitations on investment interest deductions, and the qualified business income deduction. It also addresses the tax implications for ERISA plans, tax-exempt limited partners, and non-U.S. investors, including the potential for unrelated business taxable income (UBTI) and effectively connected income (ECI). The document highlights the complexity and uncertainty of these tax rules and advises non-U.S. investors to consult with tax advisers.
documents/EFTA01390866.pdf
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