Epstein Secrets

ar (and, if necessary, subsequent years) in an amount equal to its respective share of such net decrease during such year, determined pursuant to Treasury Regulations Sections 1.704- 2(g) and 1.704-2(i)(5). The items to be so allocated shall be determined in accordance with Treasury Regulations Section 1.7042(f). This S

ebit such Capital Account by the items described in Treasury Regulations Sections 1.704-1(b)(2)(ii)(d)(4), (5) and (6). The foregoing definition of Adjusted Capital Account Deficit is intended to comply with the provisions of Treasury Regulations Section 1.704-1(b)(2)(ii)(d) and shall be interpreted consistent

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

pital Account Deficit, pro rata, in proportion to their Capital Account balances, adjusted as provided in clauses (i) and (ii) of the definition of Adjusted Capital Account Deficit, until no Member would be entitled to any further allocation, and, thereafter, to all Members, pro rata, in proportion to their resp

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

pital Account Deficit, pro rata, in proportion to their Capital Account balances, adjusted as provided in clauses (i) and (ii) of the definition of Adjusted Capital Account Deficit, until no Member would be entitled to any further allocation, and, thereafter, to all Members, pro rata, in proportion to their resp