EFTA Document EFTA01390867

GLDUS113 Cliff IllIg Section 9: Cede., Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP ECI. In the case of an investment in an Operating Partnership that is engaged in trade or business within the U.S.. the following will be considered ECI to a non-U.S. Investor: • the non-U.S. Investor's share of the items of income, gain, loss, deduction and credit derived by the Operating Partnership from a U.S. trade or business (whether or not distributed) as