GLDUS137 Forrestal Capital LLC Section 9: Cede." Legal. ERISA and Tax Considerations Glendower Capital Secondary Opportunities Fund IV, LP FATCA and other International disclosure regimes. Foreign account tax compliance. Under the Foreign Account Tax Compliance Act provisions of the Code and related U.S. Treasury guidance (-FATCA"). a withholding tax of 30% will be imposed in certain circumstances on (i) payments of certain U.S. source income (including interest and dividends) and gross proceeds from the sale or other disposition after December 31, 2018. of property that can produce U.S. source interest or dividends ("withholdable payments") and (ii) payments made after December 31.2018 (or. if later, the date on which the final U.S. Treasury regulations that define "foreign passthru payments' are published) by certain foreign financial institutions (such as barks, brokers, investment funds or certain holding companies) (TFis") that are 'attributable to withholdable payments ("foreign passthru payments'). It is uncertain at present when payments will be treated as -attributable to withholdable payments. The United Kingdom and the United States have entered into a Model 1 intergovernmental agreement (the "U.S. IGA') relating to FATCA and the United Kingdom has brought into law regulations to implement the provisions of the U.S. IGA (such regulations and any future implementing laws, rules or regulations, the 'UK MICA Legislation"). The Fund will be required to comply with the UK FATCA Legislation, which will require the Fund to undertake certain verification, due diligence and other procedures and to report to HMRC certain information about the Fund's Investors and certain U.S. persons that indirectly hold an interest in the Fund through a non-U.S. Investor. HMRC will provide this information to the IRS. So long as the Fund complies with the UK FATCA Legislation, FATCA withholding generally will not be imposed on payments made to the Fund, or on an