Fortress Intellectual Properties Opportunity Fund II, LP

Fortress Intellectual Properties Opportunity Fund II, LP

New Category LP
Investment Manager Fortress Investment Group LLC
Fund Status Open
Archive No
Custodian SEI Global Services
Jurisdiction Cayman Islands
T1135 Reporting Yes (If 10% or more income is allocated to Canadians, the T1135 reporting must be filed by the fund)
Currency USD
Tax Slip K-1 (K-1 estimates in March and K-1 final in summer)
Receiver
of Tax Receipt
RFO/Client
Tax Slips Expected

March
Statements Expected

Quarterly
Accounting
Treatment
Per K-1 for income pickup. When contributions are made you will increase the ACB of the investments and when distributions are received you will decrease the ACB of the investment until the tax information is received at year-end and then reclassify accordingly
Tax Memo/
Tax Treatment
The Partnership will own 100% of a foreign corporation (the "Blocker"). To the extent the Blocker earns passive income, Canadian investors will need to pick up their share of the FAPI generated by the Blocker. To the extent the Blocker controls other foreign corporations, they will be considered contolled foreign affiliates of the Fund and the FAPI regime will be applicable. Loans made by the Fund must also be canadianized, in order to compute the realized FX on the loan repayments.
US Tax Return Required No
Type Partnership
Nature
of Investment
Underlying is a private equity and debt related to intellectual property ("IP") investments. The Fund will acquire IP assets that are undervalued patent portfolios or companies that hold patents. The Fund will also make loans to these companies with the IP or patent as collateral.
Notes