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💨IMPACT LEVEL 1 — MEH

Epstein File EFTA01390870: Offshore and Controlled (DS10)

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

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GLDUS113 Cliff Illig Section 9: Certain Legal, ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP "**Offshore** Fund Rules"
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) may apply to an investment made by the Fund in an "**offshore** fund."
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**offshore** funds for such purposes.

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