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EFTA01451687
emplated election or adjustment under sections 734, 743 or 754 of the Code or with filing the tax returns of the Fund, any Affiliate thereof or any Portfolio Company. (e) Loans as Equity. For all U.S. tax purposes, the Fund and the Partners shall treat the Loans as equity, and not as indebtedness (as those term
EFTA01452110
emplated election or adjustment under sections 734, 743 or 754 of the Code or with filing the tax returns of the Fund, any Affiliate thereof or any Portfolio Company. (e) Loans as Equity. For all U.S. tax purposes, the Fund and the Partners shall treat the Loans as equity, and not as indebtedness (as those term