Epstein Secrets

s A Members and Class A Assignees. "Transfer" means sell, assign, pledge, grant a security interest in, grant an option to or otherwise transfer. "Unreturned Capital" as of any date and as to any Class A Member or Class A Assginee, means an amount (but not less than zero) equal to the excess of (i) the aggregate

with the Treasury Regulations under Code Section 704, in a manner that gives effect to the distribution rights of the Members and Assignees. (d) Tax Matters Partner. The Managing Member shall be the "tax matters partner" for purposes of Section 6231(aX7) of the Code. (e) Special Allocations. (1) Minimum Gain

transfer made in accordance with the terms of Section 9 hereof shall acquire and succeed to the corresponding proportionate part of the transferor's Unreturned Capital as of the date of transfer. Assignees (as defined in Section 6(e)) shall be treated as though they were Members for purposes of making distribution

the funds with which to pay such withholding taxes and the Managing Member timely fails to make payment thereof to the applicable taxing authority. Tax Matters Partner. The Manager is hereby designated as the "Tax Matters Partner" under Section 6231(a)(7) of the IRC to manage administrative tax proceedings conducte

transfer made in accordance with the terms of Section 9 hereof shall acquire and succeed to the corresponding proportionate part of the transferor's Unreturned Capital as of the date of transfer. Assignees (as defined in Section 6(e)) shall be treated as though they were Members for purposes of making distribution

the funds with which to pay such withholding taxes and the Managing Member timely fails to make payment thereof to the applicable taxing authority. Tax Matters Partner. The Manager is hereby designated as the "Tax Matters Partner" under Section 6231(a)(7) of the IRC to manage administrative tax proceedings conducte