Epstein File EFTA01354747: Offshore and Controlled (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01354747: Offshore and Controlled (DS10)

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This document is a section from a Glendower Capital Secondary Opportunities Fund IV, LP investment prospectus addressing legal, ERISA, and tax considerations for offshore fund investments. It discusses how offshore fund rules may apply to investments made by the Fund in offshore funds and explains UK tax implications for UK resident companies investing in non-UK resident companies, which may be classified as controlled foreign companies for UK tax purposes, with potential apportionment of profits and corporation tax liability.

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offshore controlled classified

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Excerpt 1

GLDUS125 Gerald Ford Section 9: Certain Legal, ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP "**Offshore** Fund Rules"

Excerpt 2

) may apply to an investment made by the Fund in an "**offshore** fund."

Excerpt 3

**offshore** funds for such purposes.