Common use of Allocation of Net Profits and Net Losses Clause in Contracts

Allocation of Net Profits and Net Losses. (a) As of the close of business each day, the Net Profits and Net Losses of each Portfolio shall be determined and allocated to and among the Holders of that Portfolio in proportion to their respective Interests in that Portfolio, determined as of the opening of business on that day. (b) Except as otherwise provided in this Section, for each taxable year of a Portfolio, all items of income, gain, loss, deduction, and credit that are recognized by that Portfolio for tax purposes shall be allocated pursuant to Treasury Regulation ss. 1.704-1(b) in a manner that equitably reflects amounts credited or debited to the Book Capital Account of each Holder of that Portfolio for such year. Allocations of such items also shall be made, where appropriate, in accordance with Section 704(c) of the Code and the regulations thereunder, as may be provided in any Policies adopted by the Trustees pursuant to Article VIII, Section 8.1(c). (c) Expenses of a Portfolio, if any, that are borne by any Holder of that Portfolio in its individual capacity shall be specially allocated to the Holder. (d) Notwithstanding anything to the contrary in the preceding paragraphs (b) or (c), if any Holder of a Portfolio unexpectedly receives any adjustments, allocations, or distributions described in Treasury Regulation xx.xx. 1.704-1(b)(2)(ii)(D)(4), (5), OR (6), items of income (including gross income) and gain of that Portfolio shall be specially allocated to the Holder in an amount and manner sufficient to eliminate the deficit balance in the Holder's Book Capital Account (as determined in accordance with Treasury Regulation ss. 1.704-1(b)(2)(ii)(D)) created by such adjustments, allocations, or distributions as quickly as possible. Any special allocations of income and gain of a Portfolio pursuant to this paragraph shall be taken into account in computing subsequent allocations of income and gain of that Portfolio pursuant to this Article, so that the net amount of any items of that Portfolio so allocated and the income, gain, loss, deductions, and other items of that Portfolio allocated to each Holder pursuant to this Article shall, to the extent possible, equal the net amount that would have been allocated to each such Holder pursuant to this Article if such special allocations had not been made.

Allocation of Net Profits and Net Losses. (a) As of the close of business each day, the Net Profits and Net Losses of each Portfolio shall be determined and allocated to and among the Holders of that Portfolio in proportion to their respective Interests in that Portfolio, determined as of the opening of business on that day. (b) Except as otherwise provided in this Section, for each taxable year of a Portfolio, all items of income, gain, loss, deduction, and credit that are recognized by that Portfolio for tax purposes shall be allocated pursuant to Treasury Regulation ss. Section 1.704-1(b) in a manner that equitably reflects amounts credited or debited to the Book Capital Account of each Holder of that Portfolio for such year. Allocations of such items also shall be made, where appropriate, in accordance with Section 704(c) of the Code and the regulations thereunder, as may be provided in any Policies adopted by the Trustees pursuant to Article VIII, Section 8.1(c). (c) Expenses of a Portfolio, if any, that are borne by any Holder of that Portfolio in its individual capacity shall be specially allocated to the Holder. (d) Notwithstanding anything to the contrary in the preceding paragraphs (b) or (c), if any Holder of a Portfolio unexpectedly receives any adjustments, allocations, or distributions described in Treasury Regulation xx.xx. Sections 1.704-1(b)(2)(ii)(D)(41(b)(2)(II)(D)(4), (5), OR (6), items of income (including gross income) and gain of that Portfolio shall be specially allocated to the Holder in an amount and manner sufficient to eliminate the deficit balance in the Holder's Book Capital Account (as determined in accordance with Treasury Regulation ssRegulation Section 1. 1.704704-1(b)(2)(ii)(D)) created by such adjustments, allocations, or distributions as quickly as possible. Any special allocations of income and gain of a Portfolio pursuant to this paragraph shall be taken into account in computing subsequent allocations of income and gain of that Portfolio pursuant to this Article, so that the net amount of any items of that Portfolio so allocated and the income, gain, loss, deductions, and other items of that Portfolio allocated to each Holder pursuant to this Article shall, to the extent possible, equal the net amount that would have been allocated to each such Holder pursuant to this Article if such special allocations had not been made.

Allocation of Net Profits and Net Losses. (a) As of the close of business each day, the Net Profits and Net Losses of each Portfolio shall be determined and allocated to and among the Holders of that Portfolio in proportion to their respective Interests in that Portfolio, determined as of the opening of business on that day. (b) Except as otherwise provided in this Section, for each taxable year of a Portfolio, all items of income, gain, loss, deduction, and credit that are recognized by that Portfolio for tax purposes shall be allocated pursuant to Treasury Regulation ss. 1.704-1(b) in a manner that equitably reflects amounts credited or debited to the Book Capital Account of each Holder of that Portfolio for such year. Allocations of such items also shall be made, where appropriate, in accordance with Section 704(c) of the Code and the regulations thereunder, as may be provided in any Policies adopted by the Trustees pursuant to Article VIII, Section 8.1(c). (c) Expenses of a Portfolio, if any, that are borne by any Holder of that Portfolio in its individual capacity shall be specially allocated to the Holder. (d) Notwithstanding anything to the contrary in the preceding paragraphs (b) or (c), if any Holder of a Portfolio unexpectedly receives any adjustments, allocations, or distributions described in Treasury Regulation xx.xxss.ss. 1.704-1(b)(2)(ii)(D)(41(b)(2)(II)(X)(0), (5), OR (6), items of income (including gross income) and gain of that Portfolio shall be specially allocated to the Holder in an amount and manner sufficient to eliminate the deficit balance in the Holder's Book Capital Account (as determined in accordance with Treasury Regulation ss. 1.704-1(b)(2)(ii)(D1(b)(2)(ii)(d)) created by such adjustments, allocations, or distributions as quickly as possible. Any special allocations of income and gain of a Portfolio pursuant to this paragraph shall be taken into account in computing subsequent allocations of income and gain of that Portfolio pursuant to this Article, so that the net amount of any items of that Portfolio so allocated and the income, gain, loss, deductions, and other items of that Portfolio allocated to each Holder pursuant to this Article shall, to the extent possible, equal the net amount that would have been allocated to each such Holder pursuant to this Article if such special allocations had not been made.

Allocation of Net Profits and Net Losses. (a) As of the close of business each day, the Net Profits and Net Losses of each Portfolio shall be determined and allocated to and among the Holders of that Portfolio in proportion to their respective Interests in that Portfolio, determined as of the opening of business on that day. (b) Except as otherwise provided in this Section, for each taxable year of a Portfolio, all items of income, gain, loss, deduction, and credit that are recognized by that Portfolio for tax purposes shall be allocated pursuant to Treasury Regulation ss. 1.704-1(b) in a manner that equitably reflects amounts credited or debited to the Book Capital Account of each Holder of that Portfolio for such year. Allocations of such items also shall be made, where appropriate, in accordance with Section 704(c) of the Code and the regulations thereunder, as may be provided in any Policies adopted by the Trustees pursuant to Article VIII, Section 8.1(c). (c) Expenses of a Portfolio, if any, that are borne by any Holder of that Portfolio in its individual capacity shall be specially allocated to the Holder. (d) Notwithstanding anything to the contrary in the preceding paragraphs (b) or (c), if any Holder of a Portfolio unexpectedly receives any adjustments, allocations, or distributions described in Treasury Regulation xx.xxss.ss. 1.704-1(b)(2)(ii)(D)(41(b)(2)(ii)(X)(0), (5), OR (6), items of income (including gross income) and gain of that Portfolio shall be specially allocated to the Holder in an amount and manner sufficient to eliminate the deficit balance in the Holder's Book Capital Account (as determined in accordance with Treasury Regulation ss. 1.704-1(b)(2)(ii)(D1(b)(2)(ii)(d)) created by such adjustments, allocations, or distributions as quickly as possible. Any special allocations of income and gain of a Portfolio pursuant to this paragraph shall be taken into account in computing subsequent allocations of income and gain of that Portfolio pursuant to this Article, so that the net amount of any items of that Portfolio so allocated and the income, gain, loss, deductions, and other items of that Portfolio allocated to each Holder pursuant to this Article shall, to the extent possible, equal the net amount that would have been allocated to each such Holder pursuant to this Article if such special allocations had not been made.