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

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each Series, the Series’ recognized profit and loss shall be allocated among the Interestholders pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses). (a) First, the Profits or Losses of the Series shall be allocated pro rata among the Interestholders based on their respective book capital accounts as of the last day of each week in which such Profits or Losses accrued. (b) Next, Disposition Gain or Disposition Loss from the Series’ trading activities for each Fiscal Year of the Trust shall be allocated among the Interestholders as follows: (i) There shall be established a tax capital account with respect to each outstanding Interest. The initial balance of each tax capital account shall be the amount paid by the Interestholder to the Series for the Interest. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: (A) Each tax capital account shall be increased by the amount of income (Profits or Disposition Gain) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(ii) and 6.3(b)(iii) below; (B) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Losses) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(iv) and 6.3(b)(v) below and by the amount of any distribution which shall have been received by the Interestholder with respect to the Interest (other than on redemption of Interests); and (C) If an Interest is redeemed, the tax capital account with respect to such Interest shall be eliminated on the Redemption Date. (ii) Disposition Gain realized during any week shall be allocated first among all Interestholders whose book capital accounts shall be in excess of their Interests’ tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholder’s excesses. (iii) Disposition Gain realized during any week that remains after the allocation pursuant to Section 6.3(b)(ii) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such week. (iv) Disposition Loss realized during any week shall be allocated first among all Interestholders whose Interests’ tax capital accounts shall be in excess of their book capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholders’ excesses. (v) Disposition Loss realized during any week that remains after the allocation pursuant to Section 6.3(b)(iv) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such calendar week. (c) The tax allocations prescribed by this Section 6.3 shall be made to each holder of an Interest whether or not the holder is a substituted Limited Owner. For purposes of this Section 6.3, tax allocations shall be made to the Managing Owner’s Interests on an Interest-equivalent basis. (d) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is intended to allocate taxable income and loss among Interestholders generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders under Section 6.2 so as to eliminate, to the extent possible, any disparity between an Interestholder’s book capital account and his tax capital account, consistent with the principles set forth in Sections 704(b) and (c)(2) of the Code. (e) Notwithstanding this Section 6.3, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book capital account of an Interest, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book capital accounts of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation).

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each Series, the Series’ ' recognized profit and loss shall be allocated among the Interestholders pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses). (a) First, the Profits or Losses of the Series shall be allocated pro rata among the Interestholders based on their respective book capital accounts as of the last day of each week in which such Profits or Losses accrued. (b) Next, Disposition Gain or Disposition Loss from the Series’ ' trading activities for each Fiscal Year of the Trust shall be allocated among the Interestholders as follows: (i) There shall be established a tax capital account with respect to each outstanding Interest. The initial balance of each tax capital account shall be the amount paid by the Interestholder to the Series for the Interest. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: : (A) Each tax capital account shall be increased by the amount of income (Profits or Disposition Gain) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(ii) and 6.3(b)(iii) below; (B) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Losses) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(iv) and 6.3(b)(v) below and by the amount of any distribution which shall have been received by the Interestholder with respect to the Interest (other than on redemption of Interests); and (C) If an Interest is redeemed, the tax capital account with respect to such Interest shall be eliminated on the Redemption Date. (ii) Disposition Gain realized during any week shall be allocated first among all Interestholders whose book capital accounts shall be in excess of their Interests’ ' tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s 's excess shall bear to all such Interestholder’s 's excesses. (iii) Disposition Gain realized during any week that remains after the allocation pursuant to Section 6.3(b)(ii) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s 's book capital account bears to all such Interestholders’ ' book capital accounts for such week. (iv) Disposition Loss realized during any week shall be allocated first among all Interestholders whose Interests’ ' tax capital accounts shall be in excess of their book capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s 's excess shall bear to all such Interestholders’ ' excesses. (v) Disposition Loss realized during any week that remains after the allocation pursuant to Section 6.3(b)(iv) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s 's book capital account bears to all such Interestholders’ ' book capital accounts for such calendar week. (c) The tax allocations prescribed by this Section 6.3 shall be made to each holder of an Interest whether or not the holder is a substituted Limited Owner. For purposes of this Section 6.3, tax allocations shall be made to the Managing Owner’s 's Interests on an Interest-equivalent basis. (d) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is intended to allocate taxable income and loss among Interestholders generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders under Section 6.2 so as to eliminate, to the extent possible, any disparity between an Interestholder’s 's book capital account and his tax capital account, consistent with the principles set forth in Sections 704(b) and (c)(2) of the Code. (e) Notwithstanding this Section 6.3, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book capital account of an Interest, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book capital accounts of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation).

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each SeriesYear, the Series’ recognized profit and loss of a Series shall be allocated among the Interestholders Owners of that Series (and among Classes of a Series as appropriate) pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses). (a) First, the Profits or Losses of the Series Trust shall be allocated pro rata among the Interestholders Owners based on their respective book capital accounts as of the last day end of each week in which such Profits or Losses accruedany Business Day. (b) Next, Disposition Gain or Disposition Loss from the Series’ Trust’s trading activities for each Fiscal Year of the Trust shall be allocated among the Interestholders Owners as follows: (i) There shall be established a tax capital account with respect to each outstanding Interest. The initial balance of each tax capital account shall be the amount paid by the Interestholder Interest Holder to the Series Trust for the Interest. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: (A) Each tax capital account shall be increased by the amount of income (Profits or Disposition Gain) which shall have been allocated to the Interestholder Interest Holder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(ii), 6.3(b)(iii) and 6.3(b)(iii6.3(b)(iv) below; (B) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Losses) which shall have been allocated to the Interestholder Interest Holder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(iv6.3(b)(v), 6.3(b)(vi) and 6.3(b)(v6.3(b)(vii) below and by the amount of any distribution which shall have been received by the Interestholder Interest Holder with respect to the Interest (other than on redemption of Interests); and (C) If an a Interest is redeemed, the tax capital account with respect to such Interest shall be eliminated on the Redemption Date. (ii) Disposition Gain realized during any week shall be allocated first to each Interest Holder, if any, who redeemed or exchanged all or a portion of his, her or its Interests up to the amount of the excess, if any, of the amount such Interest Holder received in respect of the redeemed Interests or the value of the Interests received in the exchange over the portion of the balance of such Interest Holder’s tax capital account attributable to such redeemed or exchanged Interests (the “Gain Disparity”); provided, however, that if such Disposition Gain is insufficient to cover all such allocations, it shall be allocated among such Owners in the ratio that the Gain Disparity of each such Interest Holder bears to the sum of the Gain Disparities of all such Owners. (iii) Disposition Gain that remains after the allocation pursuant to Section 6.3(b)(ii) above shall be allocated first among all Interestholders Owners whose book capital accounts shall be in excess of their Interests’ tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week6.3(b)(iii), described in Section 6.3(b)(i) above) in the ratio that each such InterestholderInterest Holder’s excess shall bear to all such InterestholderInterest Holder’s excesses. (iiiiv) Disposition Gain realized during any week that remains after the allocation pursuant to Section 6.3(b)(ii6.3(b)(iii) above shall be allocated to those Interestholders who were Interestholders during such week the Owners in the ratio that each such InterestholderInterest Holder’s book capital account bears to all such InterestholdersOwners’ book capital accounts for such weekaccounts. (ivv) Disposition Loss realized during any week shall be allocated first to each Interest Holder, if any, who redeemed or exchanged all or a portion of his, her or its Interests up to the amount of the excess, if any, of the portion of the balance of such Interest Holder’s tax capital account attributable to the redeemed or exchanged Interests over the amount such Interest Holder received in respect of the redeemed Interests or the value of the Interests received in the exchange (the “Loss Disparity”); provided, however, that if such Disposition Loss is insufficient to cover all such allocations, it shall be allocated among such Owners in the ratio that the Loss Disparity of each such Interest Holder bears to the sum of the Loss Disparities of all such Owners. (vi) Disposition Loss that remains after the allocation pursuant to Section 6.3(b)(v) above shall be allocated first among all Interestholders Owners whose Interests’ tax capital accounts shall be in excess of their book capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week6.3(b)(vi), described in Section 6.3(b)(i) above) in the ratio that each such InterestholderInterest Holder’s excess shall bear to all such InterestholdersOwners’ excesses. (vvii) Disposition Loss realized during any week that remains after the allocation pursuant to Section 6.3(b)(iv6.3(b)(vi) above shall be allocated to those Interestholders who were Interestholders during such week the Owners in the ratio that each such InterestholderInterest Holder’s book capital account bears to all such InterestholdersOwners’ book capital accounts for such calendar weekaccounts. (c) The tax allocations prescribed by this Section 6.3 shall be made to each holder of an a Interest whether or not the holder is a substituted Limited Owner. For purposes of this Section 6.3, tax allocations shall be made to the Managing Owner’s Interests on an a Interest-equivalent basis. (d) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is intended to allocate taxable income and loss among Interestholders Owners generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders Owners under Section 6.2 so as to eliminate, to the extent possible, any disparity between an Interestholdera Interest Holder’s book capital account and his tax capital account, consistent with the principles set forth in Sections 704(b) and (c)(2) of c)of the Code. Notwithstanding Section 6.3(b), if the allocations in Section 6.3(b)(ii) and 6.3(b)(v) fail to allocate Disposition Gain or Disposition Loss sufficient to eliminate the relevant Gain Disparity or Loss Disparity, the Managing Owner shall first allocate Disposition Gain or Disposition Loss in later periods to eliminate such Gain Disparity or Loss Disparity. (e) Notwithstanding this Section 6.3, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book capital account of an a Interest, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book capital accounts of the other Interests held by the same Interestholder Interest Holder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders Owners (subject to the same limitation).

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each a Series, the Series’ recognized profit and or loss of such Series shall be allocated among the Interestholders Interest Holders of such Series pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses). (a) FirstFor federal income tax purposes, the Profits items of income, gain, loss, deduction or Losses credit of the a Series for each Fiscal Year shall be allocated pro rata among the Interestholders based on their respective Interest Holders of such Series in such manner as to reflect as nearly as possible the amounts credited or charged to each Interest Holders book capital accounts as of the last day of each week account in which such Profits or Losses accruedSeries. (b) Next, Disposition Gain Unrealized gains or Disposition Loss losses of a Series from the Series’ trading activities for each Fiscal Year of the Trust shall be allocated among the Interestholders as follows: (i) There shall be established a tax capital account with respect to each outstanding Interest. The initial balance of each tax capital account shall be the amount paid by the Interestholder to the Series for the Interest. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: (A) Each tax capital account shall be increased by the amount of income (Profits or Disposition Gain) prior periods which shall have been allocated credited or charged to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(ii) and 6.3(b)(iii) below; (B) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Losses) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(iv) and 6.3(b)(v) below and by the amount of any distribution which shall have been received by the Interestholder with respect to the Interest (other than on redemption of Interests); and (C) If an Interest is redeemed, the tax capital account with respect to such Interest shall be eliminated on the Redemption Date. (ii) Disposition Gain realized during any week shall be allocated first among all Interestholders whose book capital accounts shall be in excess of their Interests’ tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholder’s excesses. (iii) Disposition Gain realized during any week that remains after the allocation pursuant to Section 6.3(b)(ii) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s Holders book capital account bears shall, when realized, be allocated as nearly as possible for federal income tax purposes to all reflect such Interestholders’ prior allocation to an Interest Holders book capital accounts for such week. (iv) Disposition Loss realized during any week shall be allocated first among all Interestholders whose Interests’ tax capital accounts shall be in excess of their book capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholders’ excesses. (v) Disposition Loss realized during any week that remains after the allocation pursuant to Section 6.3(b)(iv) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such calendar weekaccount. (c) Allocations hereunder shall be made in accordance with the Treasury Regulations promulgated by the Department of the Treasury under Section 704(b) and Section 704(c) of the Code, and in the case of allocations made in accordance with subparagraphs (a) and (b) above, may be made in accordance with the provisions in Treasury Regulation Section 1.704-3(e)(3) (or successor regulations) for securities partnerships to the extent a Series constitutes a securities partnership within the meaning of such provisions. (d) Notwithstanding subparagraph (b) above, to the extent permitted by the Treasury Regulations (or successor regulations) referred to in subparagraph (c), allocations of gains of a Series that have been realized up to the time an Interest Holder has redeemed all or any portion of his Interests in such Series may be allocated first to each Interest Holder of such Series who has redeemed any such Interests during the year to the extent that the amount the Interest Holder received on redemption exceeds the amount of the Interest Holders tax basis attributable to the Interests redeemed, and allocations of losses of a Series that have been realized up to the time an Interest Holder has redeemed all or any portion of his Interests in such Series may be allocated first to each Interest Holder of such Series who has redeemed any such Interests during the year to the extent that the amount of the Interest Holders tax basis attributable to the Interests redeemed exceeds the amount the Interest Holder received on redemption. If more than one Interest Holder receives a special allocation described above, the allocation to each Interest Holder may be made in proportion to the ratio that such Interest Holders tax basis bears to the total tax basis for all Interests of the relevant Series redeemed at that time. (e) Notwithstanding anything contained in this Trust Agreement to the contrary, the Manager shall be given the absolute discretion to make such adjustments to the allocation of gain, deduction, income, loss or distributions of a Series so that the allocations are consistent with those permitted under Subchapter K of the Code. (f) The tax allocations prescribed by this Section 6.3 shall be made to each holder of an Interest whether or not the holder is a substituted Limited Owner. For purposes of this Section 6.3, tax allocations shall be made to the Managing Owner’s Interests on an Interest-equivalent basisInterest Holder. (d) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is intended to allocate taxable income and loss among Interestholders generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders under Section 6.2 so as to eliminate, to the extent possible, any disparity between an Interestholder’s book capital account and his tax capital account, consistent with the principles set forth in Sections 704(b) and (c)(2) of the Code. (e) Notwithstanding this Section 6.3, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book capital account of an Interest, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book capital accounts of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation).

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each Seriesthe Partnership, the Series’ recognized Partnership’s realized profit and loss shall be allocated among the Interestholders Partners pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such Such allocations of profit and loss shall be pro rata from Disposition Capital Gain (or Disposition Loss) Loss and Profits (or and Losses). (a1) FirstItems of ordinary income (such as interest and credits in lieu of interest) and expense (such as management fees, incentive fees, brokerage fees, and costs in connection with the Profits or Losses organization and offering of Units in the Series Partnership including legal, accounting, auditing, preparing and printing Prospectuses, mailing costs and filing fees, and extraordinary expenses) shall be allocated pro rata among the Interestholders Partners based on their respective book capital accounts as of the last day end of each week month in which such Profits or Losses the items of ordinary income and expense accrued. (b2) Next, Disposition Capital Gain or Disposition Capital Loss from the Series’ Partnership’s trading activities for each Fiscal Year of the Trust Partnership shall be allocated among the Interestholders as follows: (ia) There For the purpose of allocating the Partnership’s Capital Gain and Capital Loss among the Partners, there shall be established a tax capital account with respect to each outstanding InterestUnit. The initial balance of each tax capital account shall be the amount paid by the Interestholder Partner to the Series Partnership for the InterestUnit. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: : (Ai) Each tax capital account shall be increased by the amount of income (Profits or Disposition Capital Gain) which shall have been allocated to the Interestholder Partner who shall hold the Interest Unit pursuant to Section 6.3(aParagraph C(1) above and Sections 6.3(b)(ii) and 6.3(b)(iiiSubparagraph (c) below; ; (Bii) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Capital Losses) which shall have been allocated to the Interestholder Partner who shall hold the Interest Unit pursuant to Section 6.3(aParagraph C(1) above and Sections 6.3(b)(iv) and 6.3(b)(vSubparagraph (e) below and by the amount of any distribution which shall have been received by the Interestholder Partner with respect to the Interest Unit (other than on redemption of InterestsUnits); and and (Ciii) If an Interest is When a Unit shall be redeemed, the tax capital account with respect to such Interest Unit shall be eliminated on the Redemption Date. (iib) Disposition Capital Gain realized during any week shall be allocated first to each Partner who has redeemed one or more of his Units during the Fiscal Year up to the excess, if any, of the amount received upon redemption of the Units over the tax capital account attributable to the redeemed Unit. (c) Capital Gain remaining after the allocation thereof pursuant to Subparagraph (b) above shall be allocated next among all Interestholders Partners whose book capital accounts shall be in excess of their InterestsUnits’ tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week, described in Section 6.3(b)(iSubparagraph (b) above) in the ratio that each such InterestholderPartner’s excess shall bear to all such InterestholderPartners’ excesses. In the event that Capital Gain to be allocated pursuant to this Subparagraph (c) shall be greater than the excess of all such Partners’ book capital accounts over all such Partners’ tax capital accounts, the excess Capital Gain shall be allocated among all Partners in the ratio that each Partner’s excessesbook capital account shall bear to all Partners’ book capital accounts. (iiid) Disposition Gain realized Capital Loss shall be allocated first to each Partner who shall have redeemed one or more of his Units during any week that remains the Fiscal Year up to the excess, if any, of the tax capital account attributable to the redeemed Units over the amount which shall have been received upon redemption of the Unit. (e) Capital Loss remaining after the allocation thereof pursuant to Section 6.3(b)(iiSubparagraph (d) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such week. (iv) Disposition Loss realized during any week shall be allocated first next among all Interestholders Partners whose InterestsUnits’ tax capital accounts shall be in excess of their book capital capital. accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week, described in Section 6.3(b)(iSubparagraph (d) above) in the ratio that each such InterestholderPartner’s excess shall bear to all such InterestholdersPartners’ excesses. (v) Disposition . In the event that Capital Loss realized during any week that remains after the allocation to be allocated pursuant to Section 6.3(b)(ivthis Subparagraph (e) above shall be greater than the excess of all such tax capital accounts over all such Partners’ book capital accounts, the excess loss shall be allocated to those Interestholders who were Interestholders during such week among all Partners in the ratio that each such InterestholderPartner’s book capital account bears shall bear to all such InterestholdersPartners’ book capital accounts for such calendar weekaccounts. (c3) The tax allocations prescribed by this Section 6.3 Paragraph C shall be made to each holder of an Interest a Unit whether or not the holder is a substituted Limited OwnerPartner. In the event that a Unit shall have been transferred pursuant to Paragraph C of Article XIV hereof, the allocations pie scribed by this Paragraph C shall be made with respect to such Unit without regard to the assignment, except that in the year of assignment the allocations prescribed by this Paragraph C shall be divided between the assignor and the assignee based on the number of months each shall have held the assigned Unit. For purposes of this Section 6.3Paragraph C, tax allocations shall be he made to the Managing OwnerGeneral Partner’s Interests Units of General Partnership Interest on an Interesta Unit-equivalent basis. (d4) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is Paragraph C shall be intended to allocate taxable income and loss among Interestholders Partners generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders Partners under Section 6.2 Paragraph B of this Article VIII so as to eliminate, to the extent possible, any disparity between an Interestholdera Partner’s book capital account and his tax capital account, . consistent with the principles set forth in Sections 704(b) and (c)(2Section 704(c)(2) of the Code. (e5) Notwithstanding the foregoing subparagraphs of this Section 6.3Paragraph E of Article VIII, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book tax capital account of an Interestany Unit, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book tax capital accounts account of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation)General Partnership Units.

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each Seriesthe Trust, the Series’ Trust’s recognized profit and loss shall be allocated among the Interestholders pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such allocations of profit and loss shall be pro rata from Disposition Gain (or Disposition Loss) and Profits (or Losses). (a) First, the Profits or Losses of the Series Trust shall be allocated pro rata among the Interestholders based on their respective book capital accounts as of the last day of each week calendar month in which such Profits or Losses accrued. (b) Next, Disposition Gain or Disposition Loss from the Series’ Trust’s trading activities for each Fiscal Year of the Trust shall be allocated among the Interestholders as follows: (i) There shall be established a tax capital account with respect to each outstanding Interest. The initial balance of each tax capital account shall be the amount paid by the Interestholder to the Series Trust for the Interest. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: (A) Each tax capital account shall be increased by the amount of income (Profits or Disposition Gain) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(ii) and 6.3(b)(iii) below; (B) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Losses) which shall have been allocated to the Interestholder who shall hold the Interest pursuant to Section 6.3(a) above and Sections 6.3(b)(iv) and 6.3(b)(v) below and by the amount of any distribution which shall have been received by the Interestholder with respect to the Interest (other than on redemption of Interests); and (C) If an Interest is redeemed, the tax capital account with respect to such Interest shall be eliminated on the Redemption Date. (ii) Disposition Gain realized during any week calendar month shall be allocated first among all Interestholders whose book capital accounts shall be in excess of their Interests’ tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current weekcalendar month, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholder’s excesses. (iii) Disposition Gain realized during any week calendar month that remains after the allocation pursuant to Section 6.3(b)(ii) above shall be allocated to those Interestholders who were Interestholders during such week month in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such weekmonth. (iv) Disposition Loss realized during any week calendar month shall be allocated first among all Interestholders whose Interests’ tax capital accounts shall be in excess of their book capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current weekcalendar month, described in Section 6.3(b)(i) above) in the ratio that each such Interestholder’s excess shall bear to all such Interestholders’ excesses. (v) Disposition Loss realized during any week calendar month that remains after the allocation pursuant to Section 6.3(b)(iv) above shall be allocated to those Interestholders who were Interestholders during such week calendar month in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such calendar weekmonth. (c) The tax allocations prescribed by this Section 6.3 shall be made to each holder of an Interest whether or not the holder is a substituted Limited Owner. For purposes of this Section 6.3, tax allocations shall be made to the Managing Owner’s Interests on an Interest-equivalent basis. (d) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is intended to allocate taxable income and loss among Interestholders generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders under Section 6.2 so as to eliminate, to the extent possible, any disparity between an Interestholder’s book capital account and his tax capital account, consistent with the principles set forth in Sections 704(b) and (c)(2) of the Code. (e) Notwithstanding this Section 6.3, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book capital account of an Interest, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book capital accounts of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation).

Allocation of Profit and Loss for United States Federal Income Tax Purposes. As of the end of each Fiscal Year of each Seriesthe Partnership, the Series’ recognized Partnership's realized profit and loss shall be allocated among the Interestholders Partners pursuant to the following subparagraphs for federal income tax purposes. Except as otherwise provided herein, such Such allocations of profit and loss shall be pro rata from Disposition Capital Gain (or Disposition Loss) Loss and Profits (or and Losses). (a1) FirstItems of ordinary income (such as interest and credits in lieu of interest) and expense (such as management fees, incentive fees, brokerage fees, and costs in connection with the Profits or Losses organization and offering of Units in the Series Partnership including legal, accounting, auditing, preparing and printing Prospectuses, mailing costs and filing fees, and extraordinary expenses) shall be allocated pro rata among the Interestholders Partners based on their respective book capital accounts as of the last day end of each week month in which such Profits or Losses the items of ordinary income and expense accrued. (b2) Next, Disposition Capital Gain or Disposition Capital Loss from the Series’ Partnership's trading activities for each Fiscal Year of the Trust Partnership shall be allocated among the Interestholders as follows: (ia) There For the purpose of allocating the Partnership's Capital Gain and Capital Loss among the Partners, there shall be established a tax capital account with respect to each outstanding InterestUnit. The initial balance of each tax capital account shall be the amount paid by the Interestholder Partner to the Series Partnership for the InterestUnit. Tax capital accounts shall be adjusted as of the end of each Fiscal Year as follows: : (Ai) Each tax capital account shall be increased by the amount of income (Profits or Disposition Capital Gain) which shall have been allocated to the Interestholder Partner who shall hold the Interest Unit pursuant to Section 6.3(aParagraph C(1) above and Sections 6.3(b)(ii) and 6.3(b)(iiiSubparagraph (c) below; ; (Bii) Each tax capital account shall be decreased by the amount of expense or loss (Losses or Disposition Capital Losses) which shall have been allocated to the Interestholder Partner who shall hold the Interest Unit pursuant to Section 6.3(aParagraph C(1) above and Sections 6.3(b)(iv) and 6.3(b)(vSubparagraph (e) below and by the amount of any distribution which shall have been received by the Interestholder Partner with respect to the Interest Unit (other than on redemption of InterestsUnits); and and (Ciii) If an Interest is When a Unit shall be redeemed, the tax capital account with respect to such Interest Unit shall be eliminated on the Redemption Date. (iib) Disposition Capital Gain realized during any week shall be allocated first to each Partner who has redeemed one or more of his Units during the Fiscal Year up to the excess, if any, of the amount received upon redemption of the Units over the tax capital account attributable to the redeemed Unit. (c) Capital Gain remaining after the allocation thereof pursuant to Subparagraph (b) above shall be allocated next among all Interestholders Partners whose book capital accounts shall be in excess of their Interests’ Units' tax capital accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(ii) for the current week, described in Section 6.3(b)(iSubparagraph (b) above) in the ratio that each such Interestholder’s Partner's excess shall bear to all such Interestholder’s Partners' excesses. In the event that Capital Gain to be allocated pursuant to this Subparagraph (c) shall be greater than the excess of all such Partners' book capital accounts over all such Partners' tax capital accounts, the excess Capital Gain shall be allocated among all Partners in the ratio that each Partner's book capital account shall bear to all Partners' book capital accounts. (iiid) Disposition Gain realized Capital Loss shall be allocated first to each Partner who shall have redeemed one or more of his Units during any week that remains the Fiscal Year up to the excess, if any, of the tax capital account attributable to the redeemed Units over the amount which shall have been received upon redemption of the Unit. (e) Capital Loss remaining after the allocation thereof pursuant to Section 6.3(b)(iiSubparagraph (d) above shall be allocated to those Interestholders who were Interestholders during such week in the ratio that each such Interestholder’s book capital account bears to all such Interestholders’ book capital accounts for such week. (iv) Disposition Loss realized during any week shall be allocated first next among all Interestholders Partners whose Interests’ Units' tax capital accounts shall be in excess of their book capital capital. accounts (after making the adjustments, other than adjustments resulting from the allocations to be made pursuant to this Section 6.3(b)(iv) for the current week, described in Section 6.3(b)(iSubparagraph (d) above) in the ratio that each such Interestholder’s Partner's excess shall bear to all such Interestholders’ Partners' excesses. (v) Disposition . In the event that Capital Loss realized during any week that remains after the allocation to be allocated pursuant to Section 6.3(b)(ivthis Subparagraph (e) above shall be greater than the excess of all such tax capital accounts over all such Partners' book capital accounts, the excess loss shall be allocated to those Interestholders who were Interestholders during such week among all Partners in the ratio that each such Interestholder’s Partner's book capital account bears shall bear to all such Interestholders’ Partners' book capital accounts for such calendar weekaccounts. (c3) The tax allocations prescribed by this Section 6.3 Paragraph C shall be made to each holder of an Interest a Unit whether or not the holder is a substituted Limited OwnerPartner. In the event that a Unit shall have been transferred pursuant to Paragraph C of Article XIV hereof, the allocations pie scribed by this Paragraph C shall be made with respect to such Unit without regard to the assignment, except that in the year of assignment the allocations prescribed by this Paragraph C shall be divided between the assignor and the assignee based on the number of months each shall have held the assigned Unit. For purposes of this Section 6.3Paragraph C, tax allocations shall be he made to the Managing Owner’s Interests General Partner's Units of General Partnership Interest on an Interesta Unit-equivalent basis. (d4) The allocation of income and loss (and items thereof) for federal income tax purposes set forth in this Section 6.3 is Paragraph C shall be intended to allocate taxable income and loss among Interestholders Partners generally in the ratio and to the extent that net profit and net loss shall be allocated to such Interestholders Partners under Section 6.2 Paragraph B of this Article VIII so as to eliminate, to the extent possible, any disparity between an Interestholder’s a Partner's book capital account and his tax capital account, . consistent with the principles set forth in Sections 704(b) and (c)(2Section 704(c)(2) of the Code. (e5) Notwithstanding the foregoing subparagraphs of this Section 6.3Paragraph E of Article VIII, if after taking into account any distributions to be made with respect to such Interest for the relevant period pursuant to Section 6.4 herein, any allocation would produce a deficit in the book tax capital account of an Interestany Unit, the portion of such allocation that would create such a deficit shall instead be allocated pro rata to the book tax capital accounts account of the other Interests held by the same Interestholder (subject to the same limitation) and, as to any balance, shall be allocated pro rata to the book capital accounts of all the remaining Interestholders (subject to the same limitation)General Partnership Units.