Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company will be “qualifying income” within the meaning of Section 7704(d) of the Code (it being understood that such income largely will result from buying and selling Commodities and that the Trading Approach is not primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members (if any) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
Appears in 15 contracts
Samples: Advisory Agreement (World Monitor Trust Ii Series E), Advisory Agreement (World Monitor Trust Ii Series F), Advisory Agreement (Diversified Futures Fund L.P.)
Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Allocated Assets will be “qualifying income” within the meaning of Section 7704(d) of the Code (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members Limited Owners (if anyas defined below) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
Appears in 5 contracts
Samples: Advisory Agreement (World Monitor Trust III - Series J), Advisory Agreement (World Monitor Trust III - Series J), Advisory Agreement (WMT III Series G/J Trading Vehicle LLC)
Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Allocated Assets will be “qualifying income” within the meaning of Section 7704(d) of the Code (it being understood that such income will largely will result from buying and selling Commodities Financial Instruments and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members Limited Owners (if anyas defined below) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
Appears in 2 contracts
Samples: Advisory Agreement (WMT III Series G/J Trading Vehicle LLC), Advisory Agreement (World Monitor Trust III - Series J)
Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Allocated Assets will be “qualifying income” within the meaning of Section 7704(d) of the Internal Revenue Code (the “Code”) (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members (if any) Limited Owners to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
Appears in 2 contracts
Samples: Advisory Agreement (World Monitor Trust III - Series J), Advisory Agreement (World Monitor Trust III - Series J)
Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Series G Allocated Assets will be “"qualifying income” " within the meaning of Section 7704(d) of the Code (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not primarily intended to generate interest incomeCommodities). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members (if any) Limited Owners to qualify for the safe harbors found in Section 864(b)(2) of the Code code and as interpreted in the regulations promulgated or proposed thereunder.
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Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Trading Vehicle Allocated Assets will be “"qualifying income” " within the meaning of Section 7704(d) of the Internal Revenue Code (the "Code") (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members (if any) Limited Owners to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
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Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Trading Vehicle Allocated Assets will be “"qualifying income” " within the meaning of Section 7704(d) of the Code (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members Limited Owners (if anyas defined below) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
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Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Trading Vehicle Allocated Assets will be “qualifying income” within the meaning of Section 7704(d) of the Internal Revenue Code (the “Code”) (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members Limited Owners (if anyas defined below) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
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Gains From Trading Approach. The Advisor agrees will endeavor that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Allocated Assets will be “qualifying income” within the meaning of Section 7704(d) of the Code (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not intended primarily intended to generate interest income). The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members Limited Owners (if anyas defined below) to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
Appears in 1 contract
Samples: Advisory Agreement (World Monitor Trust III - Series J)
Gains From Trading Approach. The Advisor agrees that at least 90% of the annual gross income and gain, if any, generated by its Trading Approach for the Company Series I Allocated Assets will be “"qualifying income” " within the meaning of Section 7704(d) of the Code theCode (it being understood that such income will largely will result from buying and selling Commodities and that the Trading Approach is not primarily intended to generate interest income). Commodities.) The Advisor also agrees that it will attempt to trade in such a manner as to allow non-U.S. Members (if any) Limited Owners to qualify for the safe harbors found in Section 864(b)(2) of the Code and as interpreted in the regulations promulgated or proposed thereunder.
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