Common use of Allocation of Profit and Loss for Federal Income Tax Purposes Clause in Contracts

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.

Appears in 12 contracts

Samples: Limited Partnership Agreement (Meritage Futures Fund L.P.), Limited Partnership Agreement (LV Futures Fund L.P.), Limited Partnership Agreement (Polaris Futures Fund L.P.)

AutoNDA by SimpleDocs

Allocation of Profit and Loss for Federal Income Tax Purposes. The As of the end of each fiscal year of the Partnership, 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 Such allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary operating 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.

Appears in 7 contracts

Samples: Limited Partnership Agreement (Morgan Stanley Smith Barney Spectrum Select Lp), Limited Partnership Agreement (Morgan Stanley Smith Barney Spectrum Strategic Lp), Limited Partnership Agreement (Ceres Tactical Currency L.P.)

Allocation of Profit and Loss for Federal Income Tax Purposes. The As of the end of each fiscal year of the Partnership, the Partnership’s realized recognized 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 Such allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary operating 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.

Appears in 5 contracts

Samples: Limited Partnership Agreement, Limited Partnership Agreement (Morgan Stanley Smith Barney Charter Aspect L.P.), Limited Partnership Agreement (Morgan Stanley Smith Barney Charter WNT L.P.)

Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership’s realized profit or loss (including As of the end of each fiscal year, the Partnership’s pro rata share of any Trading Company items) 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 purposes. Except to the extent otherwise provided below, such allocations of profit and loss will Allocations shall be pro rata from net short-term capital gain or loss and net ordinary long-term capital gain or loss and operating income or loss realized and recognized 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.

Appears in 4 contracts

Samples: Agreement of Limited Partnership (Winton Futures Fund Lp (Us)), Altegris QIM Futures Fund, L.P., Winton Futures Fund Lp (Us)

Allocation of Profit and Loss for Federal Income Tax Purposes. The As of the end of each Fiscal Year of the Partnership (or such other period as required by the Code), the Partnership’s realized recognized 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 Such allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary operating 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.

Appears in 2 contracts

Samples: Limited Partnership Agreement (Seneca Global Fund, L.P.), Limited Partnership Agreement (Aspect Global Diversified Fund LP)

AutoNDA by SimpleDocs

Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership’s realized profit or loss (including As of the end of each fiscal year, the Partnership’s pro rata share of any Trading Company items) 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 purposes. Except to the extent otherwise provided below, such allocations of profit and loss will Allocations shall be pro rata from net short‑term capital gain or loss and net ordinary long‑term capital gain or loss and operating income or loss realized and recognized 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.

Appears in 1 contract

Samples: Altegris Winton Futures Fund, L.P.

Allocation of Profit and Loss for Federal Income Tax Purposes. The Partnership’s 's realized profit or loss (including the Partnership’s '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.

Appears in 1 contract

Samples: Limited Partnership Agreement (Morgan Stanley Managed Futures MV, L.P.)

Allocation of Profit and Loss for Federal Income Tax Purposes. The As of the end of each fiscal year of a Series, the Partnership’s realized profit or loss (including the Partnership’s pro rata share of any Trading Company items) shall attributable to that Series will be allocated among the Partners pursuant to under the following subparagraphs for federal income tax purposes. Except to the extent otherwise provided below, such These allocations of profit and loss will be pro rata from net capital gain or loss and net ordinary operating income or loss realized by the Partnershipsuch Series. 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.

Appears in 1 contract

Samples: Limited Partnership Agreement (Superfund Green, L.P.)

Time is Money Join Law Insider Premium to draft better contracts faster.