Allocation of Profit and Loss for U.S. Federal Income Tax Purposes. As of the end of each fiscal year of the Partnership, the Partnership’s recognized profit or loss shall be allocated among the Partners pursuant to the following subparagraphs for federal income tax purposes. Such allocations of profit and loss shall be pro rata from net capital gain or loss and net operating income or loss realized by the Partnership. For U.S. federal income tax purposes, a distinction shall be made between net short-term gain or loss and net long-term gain or loss.
Appears in 5 contracts
Samples: Limited Partnership Agreement (Ceres Classic L.P.), Limited Partnership Agreement (Managed Futures Premier Graham L.P.), Limited Partnership Agreement (Managed Futures Premier Graham L.P.)
Allocation of Profit and Loss for U.S. Federal Income Tax Purposes. As of the end of each fiscal year of the The Partnership, ’s realized profit or loss (including the Partnership’s recognized profit or loss pro rata share of any Trading Company items) shall be allocated among the Partners pursuant to the following subparagraphs for U.S. federal income tax purposes. Such Except to the extent otherwise provided below, such allocations of profit and loss shall be pro rata from net capital gain or loss and net operating ordinary income or loss realized by the Partnership. For U.S. federal income tax purposes, a distinction shall be made between net short-term gain or loss and net long-term gain or loss.
Appears in 4 contracts
Samples: Limited Partnership Agreement (Managed Futures Premier Macro L.P.), Limited Partnership Agreement (Managed Futures Premier BHM L.P.), Limited Partnership Agreement (Managed Futures Premier BHM L.P.)