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by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distribut
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
2 mentions1 same-page
Page ?Same page
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
2 mentions1 same-page
Page ?Same page
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
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Mutual Connections (205)
Entities connected to both Distributions of Property and Allocation of Profits and Losses
the Offered Interests
ORGANIZATION3 w/ Distributions·7 w/ Allocation
Accounting Period
ORGANIZATION3 w/ Distributions·7 w/ Allocation
Reliance
ORGANIZATION3 w/ Distributions·7 w/ Allocation
the Cayman Islands
LOCATION4 w/ Distributions·4 w/ Allocation
New York
LOCATION4 w/ Distributions·4 w/ Allocation
Keogh
ORGANIZATION4 w/ Distributions·3 w/ Allocation
U.S. Treasury
ORGANIZATION4 w/ Distributions·3 w/ Allocation
Deductibility of Interest
ORGANIZATION4 w/ Distributions·3 w/ Allocation
Cayman
LOCATION4 w/ Distributions·3 w/ Allocation
Individual Limited Partners
ORGANIZATION4 w/ Distributions·3 w/ Allocation
United States
LOCATION3 w/ Distributions·4 w/ Allocation
Options and Special Allocations
ORGANIZATION3 w/ Distributions·3 w/ Allocation
Munger, Tolles & Olson LLP
ORGANIZATION3 w/ Distributions·3 w/ Allocation
New York State
LOCATION3 w/ Distributions·3 w/ Allocation
the Partnership Agreement of the Fund
ORGANIZATION3 w/ Distributions·3 w/ Allocation
a Master's in Information Systems
ORGANIZATION3 w/ Distributions·3 w/ Allocation
SL
Simon M. Lorne
PERSON3 w/ Distributions·3 w/ Allocation
the U.S. Investment Advisers Act
ORGANIZATION3 w/ Distributions·3 w/ Allocation
England
LOCATION3 w/ Distributions·3 w/ Allocation
the "Service
ORGANIZATION3 w/ Distributions·3 w/ Allocation