Epstein File EFTA01389836: Offshore and Controlled (DS10)

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Epstein File EFTA01389836: Offshore and Controlled (DS10)

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This document is a section from Glendower Capital Secondary Opportunities Fund IV, LP materials discussing legal, ERISA, and tax considerations for offshore fund investments. It addresses how UK tax rules apply to investments in non-UK resident companies classified as controlled foreign companies, and notes that profits from controlled foreign companies may be apportioned to UK resident companies for tax purposes. The document appears to be investor guidance on tax implications of offshore fund participation.

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offshore controlled classified

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Excerpt 1

GLDUS132 EverWatch Financial Section 9: Certain Legal, ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP "**Offshore** Fund

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

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**offshore** funds for such purposes.