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GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin
ather than capital gain or loss, and any Limited Partner will be subject to tax on its allocable share of such income or loss. Tax-Exempt Investors The Underlying Fund may (i) invest in operating entities that are treated as flow- through for U.S. federal income tax purposes, (ii) generate unrelated debt-financed in
GLDUS238 SOUTHERN FINANCIAL LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin
ather than capital gain or loss, and any Limited Partner will be subject to tax on its allocable share of such income or loss. Tax-Exempt Investors The Underlying Fund may (i) invest in operating entities that are treated as flow- through for U.S. federal income tax purposes, (ii) generate unrelated debt-financed in
GLOUS144 Glenn Warren Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin
ather than capital gain or loss, and any Limited Partner will be subject to tax on its allocable share of such income or loss. Tax-Exempt Investors The Underlying Fund may (i) invest in operating entities that are treated as flow- through for U.S. federal income tax purposes, (ii) generate unrelated debt-financed in
GLDUS137 Forrestal Capital LLC Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or more of the total combined votin
ather than capital gain or loss, and any Limited Partner will be subject to tax on its allocable share of such income or loss. Tax-Exempt Investors The Underlying Fund may (i) invest in operating entities that are treated as flow- through for U.S. federal income tax purposes, (ii) generate unrelated debt-financed in
Entities connected to both Controlled Foreign Corporations and The Underlying Fund