GLDUS126 Pacific Life Insurance Co Section 9: Corte., Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV. LP expenses allocable to such investments. The Fund may deduct organizational expenses rateably over 15 years. or it may elect to capitalize such expenses. No deduction is allowed for offering expenses, including placement fees. A non- corporate taxpayer is not permitted to deduct Investment interest" expense in excess of -net investment income.' This limitation could apply to limit the deductibility of interest paid by a non-corporate Investor on indebtedness incurred to finance such investors investment in the Fund or the deductibility of such investors share of interest expense (if any) of the Fund. In addition, deductions for 'business interest' may be subject to further limitations. Deductions and losses arising from an investment in the Fund may also be limited or disallowed under other rules. Qualified business income deduction. While certain non-corporate Investors may be able to deduct a portion of any -qualified business income' arising from certain trades or businesses held by the Fund, which may include investments in Operating Partnerships, for taxable years beginning before January 1, 2026, the rules in respect of such deduction are uncertain and complex. No assurance can be provided that the Fund will make investments eligible for such deduction or, if the Fund does make any such investment, that the Fund will be able to provide information necessary for such Investor to benefit from such deduction. ERISA plans and other tax-exempt limited partners. Certain organizations generally exempt from U.S. federal income tax, including ERISA plans. are subject to the tax on unrelated business taxable income CUB111. UBTI arises primarily as income from an unrelated trade or business regularly carried on, income from property as to which there is acquisition indebtedness. and certain insurance income recei