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. 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. 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 partial transfer or redemption) is equal to its or his Book Capital Account (or proportionate amount thereof in the case of a parties partial 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. As of the end of each calendar year, the Partnership’s '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 '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 '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.