This document is a section from the Glendower Capital Secondary Opportunities Fund IV, LP's Private Placement Memorandum, discussing ERISA and tax considerations for investors. It covers topics such as the deductibility of organizational expenses, limitations on investment interest expense deductions, qualified business income deductions, and tax implications for ERISA plans and non-U.S. investors. The document also addresses unrelated business taxable income (UBTI) and the potential use of a 'blocker structure' for tax-exempt investors.
doj/DataSet10/EFTA01390211.pdf
{"document_type":"legal","document_subtype":"Private Placement Memorandum","key_organizations":["Glendower Capital Secondary Opportunities Fund IV, LP"],"reference_numbers":["DB-SDNY-0094629","SDNY_GM_00240813","EFTA01390211"]}