EFTA Document EFTA01392475

GLDUS1 28 Patrick Gerschel Section 9: Oxtail Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund W. LP Ea, 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