Epstein File EFTA01383073: Offshore and Controlled (DS10)

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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01383073: Offshore and Controlled (DS10)

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This document is a section from a Glendower Capital Secondary Opportunities Fund IV, LP investment prospectus for Southern Financial LLC addressing legal, ERISA, and tax considerations for offshore fund investments. It discusses how offshore fund rules apply to Fund investments in offshore funds and explains UK tax treatment of controlled foreign companies, including potential profit apportionment and corporation tax liability for UK resident companies.

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offshore controlled

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Excerpt 1

GLDUS238 SOUTHERN FINANCIAL LLC Section 9: Certain Legal, ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP "**Offshore**

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

Excerpt 3

**offshore** funds for such purposes.