This section of the document discusses the tax considerations and legal implications for investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It covers topics such as partnership audit procedures, the lack of dividends received deduction for U.S. corporations, implications of investing in passive foreign investment companies (PFICs) and controlled foreign corporations (CFCs), and restrictions on the deductibility of expenses and losses.
doj/DataSet10/EFTA01394253.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0100251","SDNY_GM_00246435","EFTA01394253"]}