Distribution in Kind. If a withdrawing Holder receives a distribution in kind of its proportionate part of Trust property, then unrealized income, gain, loss or deduction attributable to such property shall be allocated among the Holders as if there had been a disposition of the property on the date of distribution in compliance with the requirements of Treasury Regulations Section 1.704-1(b)(2)(iv)(e).
Appears in 41 contracts
Samples: Master Custodian Agreement (High Grade Income Portfolio), Master Custodian Agreement (Mississippi Tax Free Portfolio), Custodian Agreement (Emerging Markets Portfolio)
Distribution in Kind. If a withdrawing Holder receives a distribution in kind of its proportionate part of Trust property, then unrealized income, gain, loss or deduction attributable to such property shall be allocated among the Holders as if there had been a disposition of the property on the date of distribution in compliance with the requirements of Treasury Regulations Section 1.704-1(b)(2)(iv)(e). If a withdrawing Holder receives securities other than its proportionate part of Trust Property then unrealized income, gain or loss deduction attributable to such property shall be allocated solely to such Holder as if there had been a disposition of the property on the date of distribution.
Appears in 1 contract
Samples: Master Custodian Agreement (Tax Managed Growth Portfolio)
Distribution in Kind. If a withdrawing Holder Xxxxxx receives a distribution in kind of its proportionate part of Trust property, then unrealized income, gain, loss or deduction attributable to such property shall be allocated among the Holders as if there had been a disposition of the property on the date of distribution in compliance with the requirements of Treasury Regulations Section 1.704-1(b)(2)(iv)(e).
Appears in 1 contract
Samples: Master Custodian Agreement (Floating Rate Portfolio/Ma)