individual who is a U.S. citizen or U.S. resident alien,
obtain your correct taxpayer identification number (TIN) to report, for • A partnership, corporation, company, or association created or
example, income ... Claim exemption from backup withholding if you are a U.S. exempt partner in a partnership conducting a trade or business in the United
payee. If applicable, you are also certifying ... that as a U.S. person, your States, provide Form W9 to the partnership to establish your U.S.
allocable share of any partnership income from a U.S. trade or business status
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01449423.pdf
prospective investor should read both this summary ofterms
of Glendower Access Secondary Opportunities IV (U.S), LP. (the 'Access Fund') and the summary of
terms andconditions ofGlendower CapitalSecondary Opportunities Pundit ... qualified in its entirety by reference to the Access Fund's Amended andRestatedLimited
Partnership Agreement (as amended, restated or otherwise modifiedfrom time to time, the "Partnership
Agreement'). and the subscription ... Agreements will control.
The Access Fund Glendower Access Secondary Opportunities IV (U.S.), L.P., a Delaware
limited partnership (the "Access Fund").
The General Partner The general partner of the Access Fund
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01392348.pdf
Additional Information.
(a) The Investor represents, warrants and agrees (for the benefit of the Partnership and
of any Person that participated in the offer or sale of the Interest) that ... requested by the General Partner to comply with the Partnership's
obligations under Sections 1471 through 1474 of the U.S. Internal Revenue Code, all rules, regulations and
other guidance issued ... extent such law would prevent the Partnership or the General Partner from reporting to the IRS
and/or the U.S. Treasury or any other governmental authority any information required
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EFTA01395715Set 10
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GLENDOWER ACCESS SECONDARY
OPPORTUNITIES IV (U.S.), L.P.
GENERAL PARTNER
Glendower Access Secondary Opportunities IV GP, LLC
INVESTMENT MANAGER
iCapital Advisors, LLC
STRUCTURE
Delaware Limited Partnership
STRATEGY
The Access Fund will ... INVESTMENT MANAGER
Glendower Capital SOF IV (GP) Limited
STRUCTURE
English Private Fund Limited Partnership
STRATEGY
Invest in private equity assets on the secondary market globally
MINIMUM COMMITMENT
$5 Million
FUND ... plus 2.00% and (b) 8.00%
EFTA01395717
GLDUS143 Henry Nicholas
GLENDOWER ACCESS SECONDARY OPPORTUNITIES IV (U.S.), L.P. 2
END NOTES
Note: Investors in the Access Fund will be subject to fees
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01395715.pdf
will be based on the residence of the seller.
In the case of a partnership, the determining factor is the residence of the partner. Thus, absent a
tax treaty ... losses from the sale of securities allocable to a Partner that
is a U.S. resident generally will be treated as derived from U.S. sources (even though the securities
are sold ... debt securities, receivables and payables,
will also be treated as ordinary income derived from U.S. sources.
The limitation on the foreign tax credit generally is applied separately to foreign source
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EFTA02729716Set 11
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this
by making victims independent parti
cipants in the
criminal justice process." Kenna v. U.S.
Dirt. Court for CD. Cal., 435 F.3d
1011, 1013 (9th Cir.
2006). Accordingly, because ... liberally to facilitate and accomplis
h its purposes and intent." Elliott Industries Ltd
Partnership v. BP America Productio
CI remedial legislation should be "interpret
n Co., 407 F.3d
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02729716.pdf