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atters partner shall employ experienced tax counsel to represent the Partnership in connection with any audit or investigation of the Partnership by the Internal Revenue Service and in connection with all subsequent administrative and judicial proceedings arising out of such audit. If the tax matters partner is required by
regulatory or other special needs of investors who otherwise would invest as Limited Partners of the Partnership (together with any Affiliates Fund, the "Parallel Funds"). Each Parallel Fund (other than an Affiliates Fund) shall be governed by a limited partnership agreement (or other similar constitutive document)
atters partner shall employ experienced tax counsel to represent the Partnership in connection with any audit or investigation of the Partnership by the Internal Revenue Service and in connection with all subsequent administrative and judicial proceedings arising out of such audit. If the tax matters partner is required by
egulatory or other special needs of investors who otherwise would invest as Limited Partners of the Partnership (together with any Affiliates Fund, the "Parallel Funds"). Each Parallel Fund (other than an Affiliates Fund) shall be governed by a limited partnership agreement (or other similar constitutive document)
hat, although the Partnership intends to adopt positions it believes are in accord with current interpretations of the U.S. federal income tax laws, the Internal Revenue Service ("IRS") may not agree with the tax positions taken by the Partnership and that, if challenged by the IRS, the Partnership's tax positions might not
in order to facilitate investment by certain investors (depending on applicable legal and/or tax requirements). These parallel investment vehicles (the "Parallel Funds") may be created with a legal structure which may be the same or different from that of the other Parallel Funds, but will have substantially the s
Entities connected to both the Internal Revenue Service and the "Parallel Funds

United States
LOCATION
Prince Andrew
PERSON
Samantha Power
PERSON
Eric Holder
PERSONTrigger Event
ORGANIZATION
Wilmington
LOCATIONNo Limited
ORGANIZATIONa Special Purpose Investment Fund
ORGANIZATIONAndrew McCormack
PERSONJames Fitzgerald
PERSONNONCONTRIBUTING
ORGANIZATIONNoncontributing Partners
ORGANIZATIONFinancial Accounting
ORGANIZATIONRegulated Partner
ORGANIZATIONan "Affiliated Party
ORGANIZATIONthe DOL Regulations
ORGANIZATIONPartner's Partnership Percentage
ORGANIZATIONCapital Commitments and Partnership Percentages
ORGANIZATIONthe Indemnified Party
ORGANIZATIONLabor Adv
ORGANIZATION