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ant to Section 4.2 shall be excluded from the determination of Net Profit or Net Loss. "Nonrecourse Deductions" shall have the meaning set forth in Treasury Regulations Sections 1.704-2(b)(1) and 1.704-2(c). "Non-Participating Partners" shall have the meaning assigned to it in Section 3.2(b). "Non-Voting Interest"
Market Value of such Limited Partner's Partnership Interest, in which case such Limited Partner's right to receive future distributions pursuant to Articles IV and IX shall be appropriately adjusted in good faith by the General Partner; or (v) dissolve and terminate the Partnership and distribute the Part
timate sentence of each of Treasury Regulations Sections 1.704-2(i)(5) and 1.704-2(g); and (b) debit 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 provisi
's assets. The Members shall continue to share all income, losses and distributions of the Fund during the period of liquidation in accordance with Articles IV and V. The Liquidator shall have full right and unlimited discretion to determine the time, manner and terms of any sale or sales of Fund property
enultimate sentence of each of Treasury Regulations Sections 1.704-2(i)(5) and 1.704-2(g); and debit 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 provis
s assets. The Members shall continue to share all income, losses and distributions of the Fund during the period of liquidation in accordance with Articles IV and V. The Liquidator shall have full right and unlimited discretion to determine the time, manner and terms of any sale or sales of Fund propert
Entities connected to both Treasury Regulations and Articles IV

United States
LOCATIONthe Carried Interest
ORGANIZATIONRegistrar
ORGANIZATIONthe U.S. Bank Holding Company Act
ORGANIZATIONCapital Reserves
LOCATION
Samantha Power
PERSON
the Cayman Islands
LOCATIONGeorge Town
PERSONLiquidator
ORGANIZATIONAdjusted Capital
ORGANIZATIONthe Tender Offer
ORGANIZATIONPrincipal Place of Business and Registered Offices
ORGANIZATIONCayman Corporate Centre
ORGANIZATIONWNL Limited
ORGANIZATIONthe Limited Liability Companies Law
ORGANIZATIONLong Term Insured Credit Fund
ORGANIZATIONthe Register of Limited Liability Companies
ORGANIZATIONCapital Commitments and
ORGANIZATIONAmbac Assurance UK Limited
ORGANIZATIONBallantyne Re, plc
ORGANIZATION