EFTA Document EFTA01391791

GL0US142 Ironsides Asset Mgmt Section 9: Certer Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP 'Offshore Fund Rules) may apply to an investment made by the Fund in an 'offshore fund.' The Fund itself will not constitute an offshore fund for these purposes, although it is possible that the Fund may hold or acquire investments which are offshore funds for such purposes. In such cases, all or part of an Investor's distributions attributable to any ga