Common use of Tax Basis of Basket Constituents Received Upon Redemption Clause in Contracts

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine its basis for tax purposes in any Basket Constituent it receives from the Trust in consideration for a redemption of iShares by reference to the tax basis of such Basket Constituent on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs that it receives from the Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its basis by reference to the tax basis of such Basket Constituents on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the applicable Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine its basis for tax purposes in any Basket Constituent it receives from the applicable Trust in consideration for a redemption of iShares by reference to the tax basis of such Basket Constituent on the books of the Investing Pool applicable Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs that it receives from the applicable Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the applicable Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the applicable Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its basis by reference to the tax basis of such Basket Constituents on the books of the Investing Pool applicable Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the applicable Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine its basis for tax purposes in any Basket Constituent it receives from the Trust in consideration for a redemption of iShares by reference to the tax basis of such Basket Constituent on the books of the Investing Pool Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs Index Futures that it receives from the Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs Index Futures and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its basis by reference to the tax basis of such Basket Constituents on the books of the Investing Pool Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine its basis for tax purposes in any Basket Constituent it receives from the Trust in consideration for a redemption of iShares by reference to the tax basis of such Basket Constituent on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs Index Futures that it receives from the Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs Index Futures and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its basis by reference to the tax basis of such Basket Constituents on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine treat its basis for tax purposes in any Basket Constituent it receives from the Trust in consideration for a redemption of iShares by reference to as the same as the tax basis of such Basket Constituent on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs that it receives from the Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its report such basis by reference as equal to the tax basis of such Basket Constituents on the books of the Investing Pool immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.

Tax Basis of Basket Constituents Received Upon Redemption. a. With respect to any Redemption of iShares held by an Authorized Participant for its own account, the Authorized Participant acknowledges that the basis for tax purposes in Basket Constituents that it receives from the Trust in consideration for a redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant’s basis in the iShares redeemed. The Authorized Participant will determine its basis for tax purposes in any Basket Constituent it receives from the Trust in consideration for a redemption of iShares by reference to the tax basis of such Basket Constituent on the books of the Investing Pool Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any built-in gain or loss on CERFs Index Futures that it receives from the Trust on redemption of iShares under the rules of section 1256 of the Code (absent a valid election to do otherwise), and, to the extent applicable, will report any offsetting gain or loss on the remaining iShares held by the Authorized Participant under the rules of section 475 of the Code. The Authorized Participant acknowledges that such reporting may result in a mismatch in the character or other tax attributes of gain or loss from CERFs Index Futures and iShares. b. With respect to any Redemption of iShares held by an Authorized Participant for an Authorized Participant Client, the Authorized Participant acknowledges on behalf of itself and such Authorized Participant Client that the basis for tax purposes in Basket Constituents received from the Trust in consideration for the redemption of iShares may be more or less than the fair market value of the Basket Constituents or the Authorized Participant Client’s basis in the iShares redeemed. To the extent that the Authorized Participant reports to an Authorized Participant Client, the Internal Revenue Service or any other person the basis for tax purposes of any Basket Constituents it receives from the Trust in consideration for a redemption of iShares on behalf of an Authorized Participant Client, the Authorized Participant will determine its basis by reference to the tax basis of such Basket Constituents on the books of the Investing Pool Trust immediately prior to the redemption, as such amount is reported to the Authorized Participant by the Settlement Agent, subject to adjustment as required under Section 732 or other applicable law. The Authorized Participant will report any other tax items of an Authorized Participant Client (e.g., basis in iShares, or gain or loss amounts) in a manner consistent with the preceding sentence. c. The Authorized Participant acknowledges on behalf of itself and any Authorized Participant Client that, to the extent that such Participant or Client is subject to the xxxx-to-market rules of section 475 of the Code, the basis of iShares and of any assets of the Trust and Investing Pool shall be determined for purposes of sections 734(b) and 743(b) of the Code and for the purposes of the provisions of this Article V by treating such xxxx-to-market as having no effect on such basis.. S2-6