Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership’s realized profit or loss (including the Partnership’s pro rata share of any Trading Company items) shall be allocated among the Partners pursuant to the following subparagraphs for federal income tax purposes. Except to the extent otherwise provided below, such allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary income or loss realized by the Partnership. For United States federal income tax purposes, a distinction will be made between net short-term gain or loss and net long-term gain or loss.
Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership’s realized capital gain or loss and ordinary income or loss shall be allocated among the Partners in the ratio that each Partner’s capital account bears to all Partners’ capital accounts. Any Partner who acquires or redeems Units of Limited or General Partnership Interest during any fiscal year will be allocated his proportionate share of the capital gain or loss and ordinary income or loss realized by the Partnership during the period that such Units of Limited or General Partnership Interest were owned by such Partner, based on the ratio that the capital accounts allocable to such acquired or redeemed Units of Limited or General Partnership Interest bear to the capital accounts allocable to all Partners’ Units of Limited or General Partnership Interest for such period. Any Partner who transfers or assigns Units of Limited or General Partnership Interest during any fiscal year shall be allocated his proportionate share of the capital gain or loss and ordinary income or loss realized by the Partnership through the end of the month in which notice of such transfer or assignment is given to the General Partner in accordance with Paragraph 10(b) hereof, and the transferee or assignee of such Units shall be allocated his proportionate share of the capital gain or loss and ordinary income or loss realized by the Partnership commencing with the month next succeeding the month in which notice of transfer or assignment is given. The method of allocating gains and losses for tax purposes may be changed by the General Partner upon receipt of advice from counsel to the Partnership that such change is required by applicable law or regulation.
Allocation of Profit and Loss for Federal Income Tax Purposes. As of the end of each fiscal year, the Fund’s income and expense and capital gain or loss shall be allocated among the Partners pursuant to the following provisions of this Section 7(b) for federal income tax purposes. For purposes of this Section 7(b), capital gain and capital loss shall be allocated separately and not netted.
Allocation of Profit and Loss for Federal Income Tax Purposes. As of the end of each calendar year, the Partnership’s realized profit or loss shall be allocated among the Partners for federal income tax purposes. For purposes of determining the character of the realized profit and loss allocated to each Partner for federal income tax purposes, a distinction will be made between net short-term capital gain or loss and net long-term capital gain or loss. The Partnership’s gross realized profit or loss shall be allocated first to each Partner who transferred or redeemed part or all of its or his entire general or limited partnership interest so that such Partner’s Tax Capital Account (or proportionate amount thereof in the case of a parties transfer or redemption) is equal to its or his Book Capital Account (or proportionate amount thereof in the case of a parties transfer or redemption) immediately prior to the transfer or redemption. Any remaining net realized profit or loss shall then be allocated to the Partners in order to decrease the relative differences between the Partners’ Tax Capital Account and Book Capital Account in accordance with Treasury Regulation 1.704(b)(2)(iv)(g), provided, however, that the allocations of such profit and loss to the Partners shall not exceed the allocations permitted under Subchapter K of the Code as determined by the General Partner, whose determination shall be binding. Allocations may be made in accordance with the provisions in Treasury Regulation 1.704-3(e)(3) (or successor regulations) for "securities partnerships" to the extent the Partnership constitutes a "securities partnership" within the meaning of such provisions.
Allocation of Profit and Loss for Federal Income Tax Purposes. At the end of each taxable year, each item of Partnership taxable income, gain, loss, deduction, or credit will be allocated among the Partners in accordance with the following provisions:
Allocation of Profit and Loss for Federal Income Tax Purposes. As of the end of each fiscal year, the Partnership’s income and expense and capital gain or loss from trading shall be allocated among the Partners pursuant to the following subparagraphs for federal income tax APM - Xxxxxxxx Futures Fund, L.P. Exhibit A - 4
Allocation of Profit and Loss for Federal Income Tax Purposes. As of the end of each fiscal year, the Partnership's realized profit or loss shall be allocated among the Partners pursuant to Subsections 4.3(b) and 4.3(c) below for federal income tax purposes. Such allocations of profit and loss shall be pro rata from net capital gain or loss and net operating income or loss realized by the Partnership. For United States federal income tax purposes, a distinction shall be made between net short-term capital gain or loss, net mid-term capital gain or loss and net long-term capital gain or loss.
Allocation of Profit and Loss for Federal Income Tax Purposes. As of the end of each fiscal year, the Trust’s profits or losses shall be allocated pro rata among the Unitholders for net short-term capital gain or loss, net long-term capital gain or loss, and net operating income or loss realized by the Trust as follows:
Allocation of Profit and Loss for Federal Income Tax Purposes. For each fiscal year, items of income, deduction, gain, loss or credit shall be allocated for income tax purposes among the Members in such manner as to reflect equitably amounts credited or debited to each Member's Capital Account for the current and prior fiscal years (or relevant portions thereof). Allocations shall be made pursuant to the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Regulations Sections 1.704-1(b)(2)(iv)(f), 1.704-1(b)(4)(i) and 1.704-3 promulgated thereunder, as applicable or the successor provisions to such Sections and Regulations. Notwithstanding anything to the contrary in this Agreement, there shall be allocated to the Members such gains or income as shall be necessary to satisfy the "qualified income offset" requirement of Regulations Section 1.704-1(b)(2)(ii)(d). If the Company realizes capital gains (including short-term capital gains) for federal income tax purposes ("Gains") for any fiscal year as of the end of which one or more Positive Basis Members (as hereinafter defined) withdraw from the Company pursuant to Article 9, the Managing Member may elect to allocate such gains as follows: (i) to allocate such gains among such Positive Basis Members, pro rata in proportion to the respective Positive Basis (as hereinafter defined) of each such Positive Basis Member, until either the full amount of such gains shall have been so allocated or the Positive Basis of each such Positive Basis Member shall have been eliminated and (ii) to allocate any gains not so allocated to Positive Basis Members to the other Members in such manner as shall equitably reflect the amounts credited to such Member's Capital Accounts pursuant to Section 6.2.
Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership's realized profit or loss (including the Partnership's pro rata share of any Trading Company items) shall be allocated among the Partners pursuant to the following subparagraphs for federal income tax purposes. Except to the extent otherwise provided below, such allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary income or loss realized by the Partnership. For United States federal income tax purposes, a distinction will be made between net short-term gain or loss and net long-term gain or loss. (1) Items of ordinary income and expense shall be allocated pro rata among the Partners based on their respective capital accounts as of the end of each month in which the items of ordinary income or expense accrued. (2) Net realized capital gain or loss shall be allocated as follows: (aa) For the purpose of allocating the Partnership's net realized capital gain or loss among the Partners, there shall be established an allocation account with respect to each outstanding Unit. The initial balance of each allocation account shall be the amount paid to the Partnership for the Unit. Allocation accounts shall be adjusted as of the end of each Fiscal Year and as of the date a Partner completely redeems his Units as follows: (i) Each allocation account shall be increased by the amount of income allocated to the holder of the Unit pursuant to subparagraph (c)(1) above and subparagraph (c)(2)(cc) below. (ii) Each allocation account shall be decreased by the amount of expense or loss allocated to the holder of the Unit pursuant to subparagraph (c)(1) above and subparagraph (c)(2)(ee) below and by the amount of any distribution the holder of the Unit has received with respect to the Unit (other than on redemption of the Unit). (iii) When a Unit is redeemed, (y) net realized capital gain shall first be allocated to each Partner who has redeemed all his Units up to the excess, if any, of the amount received upon redemption of his Units over the allocation account attributable to such Units and net realized capital loss shall first be allocated to each Partner who has redeemed all his Units up to the excess, if any, of the allocation account attributable to such Units over the amount received upon redemption of his Units in proportion to each such Partner's excess and (z) the allocation account with respect to such Unit shall be eliminated. (bb) After allocations, if any, pursuant to subparagraph (c)(2)(aa)(iii), net rea...
