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:
Appears in 12 contracts
Samples: Limited Partnership Agreement (LV Futures Fund L.P.), Limited Partnership Agreement (Meritage Futures Fund L.P.), Limited Partnership Agreement (Polaris Futures Fund L.P.)