This document outlines the legal, ERISA, and tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund IV, LP. It discusses the implications of engaging in U.S. trade or business, the tax rates applicable to non-U.S. investors, and the potential for U.S. federal withholding tax. It also covers the branch profits tax for non-U.S. corporate investors and the possibility of using a blocker structure for investment. Additionally, it addresses reporting requirements for U.S. investors, including forms 8865, 926, and 8938, and the potential for reportable transactions under U.S. federal tax rules.
doj/DataSet10/EFTA01394652.pdf
{"key_people":["Lawrence Hirsch"],"document_type":"legal","key_locations":["U.S."],"document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"]}