Epstein Secrets

. 3.9 Priority and Return of Capital. No Member shall have priority over any other Member, whether for the return of a Capital Contribution or for Net Profits, Net Losses, or a Distribution• provided, that this Section 3.9 shall not apply to loans or other indebtedness (as distinguished from a Capital Con

f Company income and gain (including gross income) shall be specially allocated to such Member to the extent required and in the manner specified by Treasury Regulations Sections 1.704-1(b)(2)(ii)(d) in an amount and manner sufficient to eliminate the such deficit balance as quickly as possible. This provision is intended to

is Section B-5(b) are solely for purposes of Federal and, as applicable, state and local, income tax purposes and shall not affect the allocation of Net Profits or Net Losses as between Members or any Member's Capital Account. B-6 Tar Matters Member. The Manager is hereby designated the "Tax Matters Member

n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284035 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of

is Section B-5(b) are solely for purposes of Federal and, as applicable, state and local, income tax purposes and shall not affect the allocation of Net Profits or Net Losses as between Members or any Member's Capital Account. B-6 Tar Matters Member. The Manager is hereby designated the "Tax Matters Member

n during a Company Fiscal Year, the Members shall be B - 4 404348-3-W EFTA00284052 allocated items of Company income and gain in accordance with Treasury Regulations Sections 1.704- 2(f) and 1.704-2(i)(4). (d) Qualified Income Offset. In addition, in the event that any Member has a deficit Capital Account at the end of