This document outlines the tax considerations and legal implications for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund W. LP, particularly in relation to investments in U.S. Operating Partnerships. It discusses the treatment of effectively connected income (ECI), withholding tax rates, branch profits tax, and potential use of a blocker structure for non-U.S. investors. It also covers reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the implications of reportable transactions under U.S. federal tax rules.
doj/DataSet10/EFTA01392110.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund W. LP"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}