Epstein Secrets

arc Net Gains and Net Losses and other items allocated pursuant to Article 8 and the other provisions of this Appendix II; provided however, that if the Carrying Value of any property of the Partnership differs from its adjusted basis for tax purposes, then items of income, gain, loss, deduction or credit related

GLDUS137 Forrestal Capital LLC Proprietary and Confidential account the varying interests of the Partners during such period in accordance with the requirements of Section 706(d

this Article 8 and Appendix 11 shall be made for each fiscal year of the Partnership as of the end of such fiscal year; provided, however, that if the Carrying Value of the assets of the Partnership are adjusted in accordance with clause (ii) of the definition of "Carrying Value," the date of such adjustment shal

GLDUS137 Forrestal Capital LLC Proprietary and Confidential (b) Decreased by (1) any distributions made to such Partner and (2) any amounts in the nature of loss or expense all

pursuant to Treasury Regulations under Section 704(6) of the Code) shall be treated as a deductible expense; (iv) The amount of any adjustment to the Carrying Value of any Partnership asset pursuant to Section 734(b) or Section 743(b) of the Code that is required to be reflected in the Capital Accounts of the P

GLDUS137 Forrestal Capital LLC Proprietary and Confidential List of Partners Management Agreement Management Fee Management Fee Rate Net Gain or Loss Nonrecourse Liability