Epstein Secrets

otal combined voting power or total value of the corporation's stock on any day during any taxable year. If the Access Fund invests in a CFC and is a United States Shareholder, its Limited Partners who are U.S. persons will be subject to tax under the CFC rules. As a result, each such Limited Partner must inclu

e 2017 Tax Legislation, the deferred earnings of certain foreign corporations will be deemed repatriated, and treated as if they were distributed to their United States Shareholders. Consequently, if the Access Fund invests in a foreign corporation and is a United States Shareholder, its Limited Partners who are U.

GLDUS138 Ian Slome Controlled Foreign Corporations. Special rules apply to U.S. persons who own, directly or indirectly and applying certain attribution rules, 10% or

stions about the contents of this brochure ("Brochure"), please contact us ac The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. Additional information about iCapital is also available on the SEC's

GLDUS138 Ian Slome iCapital Advisors, LLC Form ADV Part 2A ICAPITAL ADVISORS, LLC FORM ADV PART 2A Business Address 60 East 42nd Street, 26th Floor New York, NY

tions thereof, any agreements entered into pursuant to 1471(b)(1) of the Code, and all applicable intergovernmental agreements entered into between the United States and another country (or local country legislation enacted pursuant to such intergovernmental agreement). Any feeder fund (including the Offshore Ac

GLDUS138 Ian Slome Proprietary and Confidential Defaulting Access As set forth in 6.3.3. Fund Investor Defaulting Partner As set forth in 6.3.2. Delaware Act As

endower Capital. Prior to Glendower, Adam spent ten years at Deutsche Bank where he was responsible for the secondary private equity business in the Americas and led the implementation and management of secondary transactions. Prior to joining Deutsche Bank, Adam led private equity secondary and co-inves

GLDUS138 Ian Slome Section 5: Fund Management Glendower Capital Secondary Opportunities Fund IV. LP From time to tine. and as appropriate, the Manager may invite add

ugh entities treated as disregarded from their owners or as partnerships for U.S. federal income tax purposes) 'engaged in trade or business within the United States' is itself considered to be engaged in trade or business within the U.S. and is subject to U.S. federal income tax (including. possibly, in the case

GLDUS138 Ian Slome Section 9: Corte., Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV. LP expenses allocable to such investment

ts investment until the final liquidation and termination of the Partnership; (ii) that the Interest has not been, and will not be, registered under the United States Securities Act of 1933, as amended (the "Securities Act") or under the applicable securities laws of any other jurisdiction, and therefore, cannot b

GLDUS138 Ian Slome Partner may, in its sole discretion, choose not to commit up to 10% of the Limited Partners' subscriptions to the Partnership for investment into t