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es 11 Section 4.03 Borrowings 12 ARTICLE V FUND INTERESTS AND CAPITAL 13 Section 5.01 General Partner 13 Section 5.02 Limited Partners and Classes of Interests; Side Letters 13 Section 5.03 Capital Contributions. 13 Section 5.04 Admission of Limited Partners After Initial Closing; Additional Capital C
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00803533 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
es 11 Section 4.03 Borrowings 12 ARTICLE V FUND INTERESTS AND CAPITAL 13 Section 5.01 General Partner 13 Section 5.02 Limited Partners and Classes of Interests; Side Letters 13 Section 5.03 Capital Contributions. 13 Section 5.04 Admission of Limited Partners After Initial Closing; Additional Capital C
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614677 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section I .752-I(aX2
es 11 Section 4.03 Borrowings 12 ARTICLE V FUND INTERESTS AND CAPITAL 13 Section 5.01 General Partner 13 Section 5.02 Limited Partners and Classes of Interests; Side Letters 13 Section 5.03 Capital Contributions. 13 Section 5.04 Admission of Limited Partners After Initial Closing; Additional Capital C
respect to each partner nonrecourse debt (as defined in Treasury DOC ID • 26354060.5 15 EFTA00614635 Regulations Section I .704-2(bX4)) equal to the Partnership Minimum Gain that would result if such partner nonrecourse debt were treated as a nonrecourse liability (as defined in Treasury Regulations Section 1.752-1(aX2)
Entities connected to both Classes of Interests and the Partnership Minimum Gain

United States
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION
New York
LOCATION
the Cayman Islands
LOCATION
Samantha Power
PERSONthe Treasury Regulations
ORGANIZATIONthe Initial Closing
ORGANIZATIONSection 7.01 Management
ORGANIZATIONSection 9.03 Information on Investment
ORGANIZATIONSection 9.06 Limited Partners'
ORGANIZATIONOutside Activities
ORGANIZATIONARTICLE XII ACCOUNTING
ORGANIZATIONSection 12.03 Reports
ORGANIZATIONPartner Tax Basis
ORGANIZATIONThis Limited Partnership Agreement
ORGANIZATIONthe Certificate of Limited Partnership of the Fund with
ORGANIZATIONRegistered Office
ORGANIZATIONCogency Global Inc.
ORGANIZATIONthe Person or Persons
ORGANIZATION