This document outlines the tax considerations for non-U.S. investors in the Glendower Capital Secondary Opportunities Fund W. LP, particularly focusing on the implications of engaging in trade or business within the U.S. 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.
doj/DataSet10/EFTA01389833.pdf
{"document_type":"legal","key_locations":["U.S."],"document_subtype":"Confidential Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund W. LP"],"reference_numbers":["Form 8865","Form 926","Form 8938"]}