Common use of Allocations to Shareholders Clause in Contracts

Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations. (b) The Directors shall provide each Shareholder that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Series in order to facilitate compliance with Code Section 4982. (c) Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Shareholder shall be accounted for as a distribution to and charged to the Book Capital Account of such Shareholder at the time of payment of such taxes to the applicable taxing authority. The Directors may always retain from the assets belonging to a Series such amount as they may deem necessary to pay the liabilities belonging to that Series. (d) Allocations under Section 11.02(a) may be adjusted at any time by the Directors to the extent the Directors determine in good faith that such adjustments (i) would more equitably reflect the economic allocations hereunder or (ii) would otherwise be in the overall best interests of the Shareholders of a Series. (e) All decisions for each Series relating to tax matters, including, without limitation, whether to make any tax elections (including the election under Section 754 of the Code), the positions to be taken on each Series' tax returns and the settlement or further contest or litigation of any audit matters raised by the Internal Revenue Service or any other taxing authority, will be made by the Directors in their sole discretion. The Directors shall designate a "tax matters partner" for each Series for purposes of the Code; provided, however, that each such tax matters partner shall take no action (other than ministerial actions) without the consent of the Directors.

Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations. (b) The Directors shall provide each Shareholder that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Series in order to facilitate compliance with Code Section 4982. (c) Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Shareholder shall be accounted for as a distribution to and charged to the Book Capital Account of such Shareholder at the time of payment of such taxes to the applicable taxing authority. The Directors may always retain from the assets belonging to a Series such amount as they may deem necessary to pay the liabilities belonging to that Series. (d) Allocations under Section 11.02(a) may be adjusted at any time by the Directors to the extent the Directors determine in good faith that such adjustments (i) would more equitably reflect the economic allocations hereunder or (ii) would otherwise be in the overall best interests of the Shareholders of a Series. (e) All decisions If a Series realizes capital gains or losses for each Series relating to federal income tax matterspurposes (collectively, including, without limitation, whether to make "gains/losses") for any tax elections (including the election under Section 754 taxable year during or as of the Code)end of which one or more Adjusted Basis Shareholders (as defined below) of that Series redeems Shares of that Series pursuant to Section 9.02 or transfers Shares of that Series pursuant to Section 2.06, the positions to be taken on each Series' tax returns and the settlement or further contest or litigation of any audit matters raised by the Internal Revenue Service or any other taxing authorityDirectors may, will be made by the Directors in their sole discretion. The Directors shall designate a "tax matters partner" for each Series for purposes : (i) allocate such gains/losses among such Adjusted Basis Shareholders, pro rata in proportion to the respective Adjusted Basis (as defined below) of the Code; provided, however, that each such tax matters partner Adjusted Basis Shareholder, until either the full amount of such gains/losses shall take no action have been so allocated or the Adjusted Basis of each such Adjusted Basis Shareholder shall have been eliminated, and (other than ministerial actionsii) without allocate any gains/losses not so allocated to Adjusted Basis Shareholders to the consent of the DirectorsShareholders in accordance with Section 11.02(a) hereof.

Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's Shareholders Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations. (b) The Directors shall provide each Shareholder that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Series in order to facilitate compliance with Code Section 4982. (c) Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Shareholder shall be accounted for as a distribution to and charged to the Book Capital Account of such Shareholder at the time of payment of such taxes to the applicable taxing authority. The Directors may always retain from the assets belonging to a Series such amount as they may deem necessary to pay the liabilities belonging to that Series. (d) Allocations under Section 11.02(a) may be adjusted at any time by the Directors to the extent the Directors determine in good faith that such adjustments (i) would more equitably reflect the economic allocations hereunder or (ii) would otherwise be in the overall best interests of the Shareholders of a Series. (e) All decisions for each Series relating to tax matters, including, without limitation, whether to make any tax elections (including the election under Section 754 of the Code), the positions to be taken on each Series' Series tax returns and the settlement or further contest or litigation of any audit matters raised by the Internal Revenue Service or any other taxing authority, will be made by the Directors in their sole discretion. The Directors shall designate a "tax matters partner" for each Series for purposes of the Code; provided, however, that each such tax matters partner shall take no action (other than ministerial actions) without the consent of the Directors.

Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's ’s Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations. (b) The Directors shall provide each Shareholder that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Series in order to facilitate compliance with Code Section 4982. (c) Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Shareholder shall be accounted for as a distribution to and charged to the Book Capital Account of such Shareholder at the time of payment of such taxes to the applicable taxing authority. The Directors may always retain from the assets belonging to a Series such amount as they may deem necessary to pay the liabilities belonging to that Series. (d) Allocations under Section 11.02(a) may be adjusted at any time by the Directors to the extent the Directors determine in good faith that such adjustments (i) would more equitably reflect the economic allocations hereunder or (ii) would otherwise be in the overall best interests of the Shareholders of a Series. (e) All decisions If a Series realizes capital gains or losses for each Series relating to federal income tax matterspurposes (collectively, including, without limitation, whether to make "gains/losses7') for any tax elections (including the election under Section 754 taxable year during or as of the Code)end of which one or more Adjusted Basis Shareholders (as defined below) of that Series redeems Shares of that Series pursuant to Section 9.02 or transfers Shares of that Series pursuant to Section 2.06, the positions to be taken on each Series' tax returns and the settlement or further contest or litigation of any audit matters raised by the Internal Revenue Service or any other taxing authorityDirectors may, will be made by the Directors in their sole discretion. The Directors shall designate a "tax matters partner" for each Series for purposes : (i) allocate such gains/losses among such Adjusted Basis Shareholders, pro rata in proportion to the respective Adjusted Basis (as defined below) of the Code; provided, however, that each such tax matters partner Adjusted Basis Shareholder, until either the full amount of such gains/losses shall take no action have been so allocated or the Adjusted Basis of each such Adjusted Basis Shareholder shall have been eliminated, and (other than ministerial actionsii) without allocate any gains/losses not so allocated to Adjusted Basis Shareholders to the consent of the DirectorsShareholders in accordance with Section 11.02(a) hereof.

Allocations to Shareholders. (a) Items of income, deduction, gain, loss or credit of each Series will be allocated for federal income tax purposes among the Shareholders of that Series in a manner so as to reflect equitably amounts credited or debited to each Shareholder's ’s Book Capital Account for that Series for the current and prior taxable years (or relevant portions of those years). Allocations under this Section 11.02(aArticle XI.02 (a) will be made in accordance with the principles of Sections 704(b) and 704(c) of the Code, and in conformity with Treasury Regulations promulgated under these sections, or the successor provisions to such sections and Treasury Regulations. (b) The Directors shall provide each Shareholder that is a regulated investment company, as defined in Section 851(a) of the Code, information that will enable it to take into account its share of items of taxable income, gain, loss and deduction as they are taken into account by the Series in order to facilitate compliance with Code Section 4982. (c) Any income tax withholding or other withholding of taxes required by law with respect to the allocable share of income of, or distributions to, a Shareholder shall be accounted for as a distribution to and charged to the Book Capital Account of such Shareholder at the time of payment of such taxes to the applicable taxing authority. The Directors may always retain from the assets belonging to a Series such amount as they may deem necessary to pay the liabilities belonging to that Series. (d) Allocations under Section 11.02(aArticle XI.02(a) may be adjusted at any time by the Directors to the extent the Directors determine in good faith that such adjustments (i) would more equitably reflect the economic allocations hereunder or (ii) would otherwise be in the overall best interests of the Shareholders of a Series. (e) All decisions If a Series realizes capital gains or losses for each Series relating to federal income tax matterspurposes (collectively, including, without limitation, whether to make “gains/losses”) for any tax elections (including the election under Section 754 taxable year during or as of the Code)end of which one or more Adjusted Basis Shareholders (as defined below) of that Series redeems Shares of that Series pursuant to Article IX.02 or transfers Shares of that Series pursuant to Article II.06, the positions to be taken on each Series' tax returns and the settlement or further contest or litigation of any audit matters raised by the Internal Revenue Service or any other taxing authorityDirectors may, will be made by the Directors in their sole discretion. The Directors : (i) allocate such gains/losses among such Adjusted Basis Shareholders, as determined by the Directors, until either the full amount of such gain/loss shall designate a "tax matters partner" for each Series for purposes have been so allocated or the Adjusted Basis of the Code; provided, however, that each such tax matters partner Adjusted Basis Shareholder shall take no action have been eliminated, and (other than ministerial actionsii) without the consent of the Directorsallocate any gains/losses not so allocated to Adjusted Basis Shareholders to Shareholders in accordance with Article XI.02(a) and (d) hereof.