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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01389410: Endowment, Offshore and Controlled (DS10)

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This document is a section from the Glendower Capital Secondary Opportunities Fund IV, LP prospectus addressing legal, ERISA, and tax considerations for the Georgetown University Endowment. It discusses offshore fund regulations, controlled foreign company rules applicable to UK resident companies, and tax implications of investing in non-UK resident companies and offshore funds.

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GLDUS133 Georgetown University Endowment Section 9: Certain Legal, ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP "**Offshore**
Excerpt 2
Fund Rules") may apply to an investment made by the Fund in an "**offshore** fund."
Excerpt 3
**offshore** funds for such purposes.

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