Common use of Tax Conventions Clause in Contracts

Tax Conventions. (a) For purposes of Sections 6.1, 6.2, and 6.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.6) during the month in which such Shares are issued or redeemed. In the event that the Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among the Shareholders recognized as shareholders of the Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund who own Shares as of the close of the day in which such gain or loss is recognized for federal income tax purposes. (c) The allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) and to take into account a Shareholder’s or Shareholders’ varying interests during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.17.1, 6.27.2, and 6.37.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 7.4(b). (i) All issuances, redemptions and transfers of Shares Units or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share Unit or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share Unit is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.6) during the month in which such Shares are issued or redeemed. In the event that the a Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.67.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among to the Shareholders Unitholders recognized as shareholders Unitholders of the a Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share Unit during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Unitholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Unitholders who own Shares Units as of the close of the day in which such gain or loss is recognized for federal income tax purposes. Investors who hold a Unit on the last trading day of the first month of a Fund’s operation will be allocated the tax items for that month, as well as the tax items for the following month, attributable to the Unit. (c) The allocations pursuant to Section 6.4(b7.4(b) are intended to constitute a reasonable method comply with permissible methods of allocation allocations permitted in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) 4 and to take into account a ShareholderUnitholder’s or ShareholdersUnitholders’ varying interests Units during the taxable year of any issuance, redemption or transfer of Shares Units or beneficial interests therein. Any person who is the transferee of Shares Units shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 Section 7.4(b), and 6.4 in any other provision of this Article VII, as a condition of receiving such SharesUnits.

Tax Conventions. (a) For purposes of Sections 6.17.1, 6.27.2, and 6.37.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 7.4(b). (i) All issuances, redemptions and transfers of Shares Units or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share Unit or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share Unit is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.6) during the month in which such Shares are issued or redeemed. In the event that the a Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.67.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among to the Shareholders Unitholders recognized as shareholders Unitholders of the a Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share Unit during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Unitholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Unitholders who own Shares Units as of the close of the day in which such gain or loss is recognized for federal income tax purposes. Investors who hold a Unit on the last trading day of the first month of a Fund’s operation will be allocated the tax items for that month, as well as the tax items for the following month, attributable to the Unit. (c) The allocations pursuant to Section 6.4(b7.4(b) are intended to constitute a reasonable method comply with permissible methods of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) 4 and to take into account a ShareholderUnitholder’s or ShareholdersUnitholders’ varying interests Units during the taxable year of any issuance, redemption or transfer of Shares Units or beneficial interests therein. Any person who is the transferee of Shares Units shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 Section 7.4(b), and 6.4 in any other provision of this Article VII, as a condition of receiving such SharesUnits.

Tax Conventions. (a) For purposes of Sections 6.17.1, 6.27.2, and 6.37.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 7.4(b). (i) All issuances, redemptions and transfers of Shares units or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share Unit or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share Unit is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d7.1(c), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares units shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67.6) during the month in which such Shares units are issued or redeemed. In the event that the a Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.67.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among to the Shareholders Unitholders recognized as shareholders unitholders of the a Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share Unit during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Unitholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Unitholders who own Shares units as of the close of the day in which such gain or loss is recognized for federal income tax purposes. Investors who hold a Unit on the last trading day of the first month of a Fund’s operation will be allocated the tax items for that month, as well as the tax items for the following month, attributable to the Unit. (c) The allocations pursuant to Section 6.4(b7.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) and to take into account a Shareholderunitholder’s or ShareholdersUnitholders’ varying interests units during the taxable year of any issuance, redemption or transfer of Shares units or beneficial interests therein. Any person who is the transferee of Shares units shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 Section 7.4(b), and 6.4 in any other provision of this Article VII, as a condition of receiving such Sharesunits.

Tax Conventions. (a) For purposes of Sections 6.1, 6.2, and 6.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 6.5(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.66.7) during the month in which such Shares are issued or redeemed. In the event that the Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 6.7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each Each item of a Fund’s income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders who own Shares of the Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing; provided that, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a the Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund who own Shares as of the close of the day in which such gain or loss is recognized for federal income tax purposes. (c) The allocations pursuant to Section 6.4(bsection 6.5(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) and to take into account a Shareholder’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 6.4 and 6.4 6.5 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeAgreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for U.S. federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.17.1, 6.27.2, and 6.37.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 7.4(b). (i) All issuances, redemptions and transfers of Shares Units or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share Unit or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share Unit is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d7.1(c), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares Units shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67.6) during the month in which such Shares Units are issued or redeemed. In the event that the a Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.67.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among to the Shareholders Unitholders recognized as shareholders unitholders of the a Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share Unit during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Unitholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Unitholders who own Shares Units as of the close of the day in which such gain or loss is recognized for federal income tax purposes. Investors who hold a Unit on the last trading day of the first month of a Fund’s operation will be allocated the tax items for that month, as well as the tax items for the following month, attributable to the Unit. (c) The allocations pursuant to Section 6.4(b7.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) and to take into account a ShareholderUnitholder’s or ShareholdersUnitholders’ varying interests Units during the taxable year of any issuance, redemption or transfer of Shares Units or beneficial interests therein. Any person who is the transferee of Shares Units shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 Section 7.4(b), and 6.4 in any other provision of this Article VII, as a condition of receiving such SharesUnits.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and Section 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeTrust Agreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and Section 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeTrust Agreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for U.S. federal income tax purposes. (c) The . All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the Sponsor’s 's reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust's income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner's Shares. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s 's reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust's income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Sponsor's Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the "single monthly price"). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeAgreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s 's reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the Sponsor’s 's sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for U.S. federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a Shareholder’s Beneficial Owner or Shareholders’ Beneficial Owner's varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. [[In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price]]. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeAgreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the Sponsor’s Trustee's reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust's income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner's Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the Sponsor’s Trustee's reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust's income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee's Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the "single monthly price"). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeAgreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the Sponsor’s Trustee's reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the Sponsor’s Trustee's sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for U.S. federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a Shareholder’s Beneficial Owner or Shareholders’ Beneficial Owner's varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.17.1, 6.27.2, and 6.37.3, the Sponsor or Administrator shall adopt such conventions as may be necessary, appropriate or advisable in the Sponsor’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder. The Sponsor may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous sentence.. Table of Contents (b) Unless the Sponsor determines that another convention is necessary or appropriate in the Sponsor’s reasonable discretion in order to comply with applicable law, each Fund shall use the monthly convention described in this Section 6.4(bsection 7.4(b). (i) All issuances, redemptions and transfers of Shares Units or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share Unit or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share Unit is lowest. Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d7.1(c), the fair market value of all Fund property immediately prior to the issuance, redemption or transfer of Shares Units shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67.6) during the month in which such Shares Units are issued or redeemed. In the event that the a Fund makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All property contributed to a Fund shall be deemed to have a value equal to the value of such property (determined under principles similar to those described in Section 6.67.6) on the date of such contribution. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale price of the property, respectively. (iii) In general, each item of a Fund’s income, gain, expense, loss, deduction and credit shall, for U.S. federal income tax purposes, be determined for each calendar month during a taxable period based on an interim closing of the books and shall be allocated solely among to the Shareholders Unitholders recognized as shareholders unitholders of the a Fund as of the close of business on the last trading day of the preceding calendar month. For this purpose, any transfer of a Share Unit during a calendar month shall be treated as being effective immediately prior to the close of business on the last trading day of a calendar month. Notwithstanding the foregoing, unless the Sponsor determines that another method is necessary or appropriate in the Sponsor’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund (or, in the Sponsor’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Unitholders in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Unitholders who own Shares Units as of the close of the day in which such gain or loss is recognized for federal income tax purposes. Investors who hold a Unit on the last trading day of the first month of a Fund’s operation will be allocated the tax items for that month, as well as the tax items for the following month, attributable to the Unit. (c) The allocations pursuant to Section 6.4(b7.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section 1.706-1(c)(2)(ii) and to take into account a ShareholderUnitholder’s or ShareholdersUnitholders’ varying interests Units during the taxable year of any issuance, redemption or transfer of Shares Units or beneficial interests therein. Any person who is the transferee of Shares Units shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 Section 7.4(b), and 6.4 in any other provision of this Article VII, as a condition of receiving such SharesUnits.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and Section 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeTrust Agreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for U.S. federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.

Tax Conventions. (a) For purposes of Sections 6.11, 6.2, 2 and 6.33, the Sponsor or Administrator Trustee shall cause the Trust to adopt such conventions as may be necessary, necessary or appropriate or advisable in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, including Section 706 of the Code and the Treasury Regulations or rulings promulgated thereunder, or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that reflects Beneficial Owner’s Shares. The Sponsor Trustee may revise, alter or otherwise modify such conventions in accordance with the standard established in the previous prior sentence. (b) Unless the Sponsor Trustee determines that another convention is necessary or appropriate in the SponsorTrustee’s reasonable discretion in order to comply with applicable law, each Fund or to allocate items of the Trust’s income, gain, loss, expenses, deductions and credits in a manner that more accurately reflects Trustee’s Shares, the Trust shall use the monthly convention described in this Section 6.4(b4(b). (i) All issuances, redemptions and transfers of Shares or beneficial interests therein shall be deemed to take place at a price (the “single monthly price”) equal to the value of such Share or beneficial interest therein at the end of the Business Day during the month in which the issuance, redemption or transfer takes place on which the value of a Share is lowestlowest (such price, the “single monthly price”). Accordingly, in determining Unrealized Gain or Unrealized Loss and in making the adjustments provided for by Section 6.1(d1(d), the fair market value of all Fund Trust property immediately prior to the issuance, redemption or transfer of Shares shall be deemed to be equal to the lowest value of such property (as determined under Section 6.67) during the month in which such Shares are issued or redeemed. In the event that the Fund Trust makes an election under Section 754 of the Code, adjustments to be made under Sections 734(b) and Section 743(b) of the Code will be made using the same monthly convention, including by reference to the single monthly price. (ii) All contributed property contributed to a Fund shall be deemed to have be contributed at a value price equal to the weighted average value of such property (as determined under principles similar to those described Section 7) during the month in Section 6.6) on the date of which such contributionproperty is contributed. All purchases and sales of property, however, shall be treated as taking place at a price equal to the purchase or sale sales price of the property, respectively. (iii) In general, each Each item of a Fund’s Trust income, gain, expense, loss, deduction and credit attributable to transferred Shares shall, for U.S. federal income tax purposes, be determined for each calendar month during on a taxable period based on an interim closing of the books monthly basis and shall be allocated solely among to the Shareholders recognized as shareholders of the Fund Beneficial Owners who own Shares as of the close of business the last day of the month preceding the month in which the transfer occurs, provided that, for the initial period beginning on the date hereof and ending on the last trading day of the preceding calendar month. For month following the month in which this purposeAgreement becomes effective, any transfer of a Share during a calendar month such items shall be treated allocated to the Beneficial Owners who own the Shares as being effective immediately prior to of the close of business on the last trading day of a calendar month. Notwithstanding the foregoingmonth in which such items arose; and provided further that, unless the Sponsor Trustee determines that another method is necessary or appropriate in the SponsorTrustee’s reasonable discretion, gain or loss on a sale or other disposition of all or a substantial portion of the assets of a Fund the Trust (or, in the SponsorTrustee’s sole discretion, other sales or dispositions of assets if appropriate to more accurately allocate such gain and loss to Shareholders Beneficial Owners in a manner that corresponds to their economic gain and loss) shall be allocated to the Shareholders of the Fund Beneficial Owners who own Shares as of the close of the day in which such gain or loss is recognized for federal income tax purposes. (civ) The All such allocations pursuant to Section 6.4(b) are intended to constitute a reasonable method of allocation in accordance with Treasury Regulations section Section 1.706-1(c)(2)(ii) and to take into account a ShareholderBeneficial Owner or Beneficial Owner’s or Shareholders’ varying interests Shares during the taxable year of any issuance, redemption or transfer of Shares or beneficial interests therein. Any person who is the transferee of Shares shall be deemed to consent to the methods of determination and allocation set forth in Sections 6.3 and 6.4 this Section 4 as a condition of receiving such Shares.