Common use of Allocations for Tax Purposes Clause in Contracts

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.3, each item of income, gain, loss, deduction and credit of a Fund shall be allocated among the Unitholders in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted Property, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders under the principles of the remedial method of Treasury Regulations section 1.704-3(d). (c) If any Unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c). (d) The provisions of this Article VII and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.33, each item of income, gain, loss, deduction and credit of a Fund the Trust shall be allocated among the Unitholders Beneficial Owners in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted PropertyDisparities, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders Beneficial Owners under the principles of the remedial method of Treasury Regulations section Section 1.704-3(d). (c) If any Unitholder Beneficial Owner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder Beneficial Owner in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c2(c). (d) The provisions of this Article VII Annex I and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section Section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator Administrative Trustee shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 Article III if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.33, each item of income, gain, loss, deduction and credit of a Fund the Trust shall be allocated among the Unitholders Beneficial Owners in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted PropertyDisparities, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders Beneficial Owners under the principles of the remedial method of Treasury Regulations section Section 1.704-3(d). (c) If any Unitholder Beneficial Owner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder Beneficial Owner in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c2(c). (d) The provisions of this Article VII Annex I and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section Section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator Trustee shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.3, each item of income, gain, loss, deduction and credit of a Fund shall be allocated among the Unitholders in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted Property, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders under the principles of the remedial method of Treasury Regulations section 1.704-3(d). (c) If any Unitholder unitholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder unitholder in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c). (d) The he provisions of this Article VII and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.36.4, each item of income, gain, loss, deduction and credit of a Fund shall be allocated among the Unitholders Shareholders in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted Property, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders Shareholders under the principles of the remedial method of Treasury Regulations section 1.704-3(d). (c) If any Unitholder Shareholder unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder Shareholder in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c6.2(c). (d) The provisions of this Article VII VI and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 6.3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.33, each item of income, gain, loss, deduction and credit of a Fund the Trust shall be allocated among the Unitholders Beneficial Owners in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted PropertyDisparities, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders Beneficial Owners under the principles of the remedial method of Treasury Regulations section Section 1.704-3(d). (c) If any Unitholder Beneficial Owner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder Beneficial Owner in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c2(c). (d) The provisions of this Article VII Annex I and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section Section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator Administrative Trustee shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.

Allocations for Tax Purposes. (a) For U.S. federal income tax purposes, except as otherwise provided in this Section 7.33, each item of income, gain, loss, deduction and credit of a Fund the Trust shall be allocated among the Unitholders Beneficial Owners in accordance with their respective Percentage Interests. (b) In an attempt to eliminate Book-Tax Disparities attributable to Adjusted PropertyDisparities, items of income, gain, or loss shall be allocated for U.S. federal income tax purposes among the Unitholders Beneficial Owners under the principles of the remedial method of Treasury Regulations section Section 1.704-3(d). (c) If any Unitholder Beneficial Owner unexpectedly receives any adjustments, allocations or distributions described in Treasury Regulations Section 1.704-1(b)(2)(ii)(d), items of income and gain shall be specially allocated to such Unitholder Beneficial Owner in an amount and manner consistent with the allocations of income and gain pursuant to Section 7.2(c2(c). (d) The provisions of this Article VII Annex I and the other provisions of this Trust Agreement relating to the maintenance of Capital Accounts are intended to comply with Treasury Regulations section Section 1.704-1(b) and shall be interpreted and applied in a manner consistent with such Regulations. The Sponsor or Administrator Trustee shall be authorized to make appropriate amendments to the allocations of items pursuant to this Section 7.3 3 if necessary in order to comply with Section 704 of the Code or applicable Treasury Regulations thereunder.