Capital Accounts and Allocations. (a) CAPITAL ACCOUNTS. A separate capital account (a "Capital Account") shall be established and maintained for each Member, which shall initially be equal to the Capital Contribution of such Member as set forth on Schedule A hereto. Such Capital Accounts shall be maintained in accordance with Section 1.704-1(b)(2)(iv) of the Treasury Regulations, and this Section 5.2 shall be interpreted and applied in a manner consistent with said Section of the Treasury Regulations. The Capital Accounts shall be maintained for the sole purpose of allocating items of income, gain, loss and deduction among the Members and shall have no effect on the amount of any distributions to any Members in liquidation or otherwise. The amount of all distributions to Members shall be determined pursuant to Sections 5.3, 5.4 and 5.5.
Capital Accounts and Allocations. A capital account shall be established for each Unit, and for the General Partner on a Unit-equivalent basis. The initial balance of each Unit’s capital account shall be the amount contributed to the Fund with respect to such Unit, which amount shall be equal to the Net Asset Value per Unit on the date each Unit is purchased after all accrued fees and expenses (other than organizational and initial offering cost reimbursement payments, which shall be taken into account only on a cash basis), including profit share accruals which may, in fact, never be paid. As of the close of business (as determined by the General Partner) on the last day of each month, any increase or decrease in the Fund’s Net Assets as compared to the last such determination of Net Assets shall be credited or charged equally to the capital accounts of all Units then outstanding; provided that for purposes of maintaining such capital accounts, amounts paid or payable to the General Partner for items such as reimbursement of organizational and initial offering costs and service fees shall be treated as if paid or payable to a third party and shall not be credited to the capital account or the interest held by the General Partner. For purposes of this Section 7, unless specified to the contrary, Units redeemed as of the end of any month shall be considered outstanding as of the end of such month.
Capital Accounts and Allocations. (a) A separate capital account (a "Capital Account") shall be maintained on the Partnership's books for each Partner. In the event any Interest is transferred in accordance with the terms of this Agreement, the transferee shall succeed to the Capital Account of the transferor to the extent it relates to the transferred Interest.
Capital Accounts and Allocations. A separate capital account shall be established and maintained for each Shareholder in a manner intended to be in accordance with Section 704 of the Code and regulations thereunder. Subject to Section 704 of the Code and regulations thereunder, the income, expenses, gains, losses, deductions and credits of the Trust shall be allocated among the Shareholders’ capital accounts so as to conform, in the judgment of the Trustees, as nearly as practicable to the related distributions and expected distributions (including amounts that would be distributed to each Shareholder pursuant to Section 8.2 if the Trust were terminated) pursuant to this Declaration of Trust. The Board of Trustees, in consultation with the Trust’s tax advisor, is authorized to interpret the capital account provisions of this Declaration of Trust and determine the allocation methodologies to be used as it determines appropriate in its sole discretion and (a) to interpret and apply the allocation provisions hereof as providing for a “qualified income offset,” “minimum gain chargeback” and such other allocation principles as may be required under Section 704 of the Code and applicable regulations; (b) to determine the allocation of specific items of income, gain, loss, deduction and credit of the Trust; and (c) to vary any and all of the foregoing allocation provisions to the extent necessary or advisable in the judgment of the Board of Trustees to comply with Section 704 of the Code and applicable regulations. The Board of Trustees shall have the power and authority to make all accounting, tax and financial determinations and decisions with respect to the Trust.
Capital Accounts and Allocations. 14 7.1 Capital Contributions of Partners..............................................................14 7.2 Withdrawal of Capital..........................................................................14 7.3
Capital Accounts and Allocations. A capital account shall be established for each Unit and for the Managing Owner. The initial balance of each capital account shall be the aggregate amount contributed to the Trust with respect to a Unit, which amount shall be equal to the Net Asset Value per Unit on the date each Unit is purchased after all accrued fees, expenses and Incentive Fee allocations (other than unamortized organizational and initial offering costs). As of the close of business (as determined by the Managing Owner) on the last business day of each month, any increase or decrease in the Trust’s Net Assets as compared to the last such determination of Net Assets shall be credited or charged equally to the Units of all Unitholders. In making the month-end adjustments to the capital accounts described in the preceding paragraph, capital accounts of all Units shall be adjusted to reflect the Brokerage Fee as defined in Section 8(c).
Capital Accounts and Allocations. The tax consequences of an investment in the Fund to a Shareholder in the event of dissolution depend on the Shareholder's capital account and on the allocations of profits and losses to that account. The Fund's taxable profits or losses are allocated among the Shareholders as described below and profits or losses are added to or subtracted from the Shareholders' capital accounts. The amounts allocated to each Shareholder will generally not be equal to the distributions the Shareholder receives until final liquidating distributions are made to Shareholders. Each Shareholder will have a capital account, which will have an initial balance equal to the Shareholder's Capital Contribution. Capital accounts will be adjusted in accordance with Regulations under Code Section 704. The capital account balance will be increased by any additional Capital Contributions by the Shareholder and by profits allocated to the Shareholder; it will be decreased by the amount of distributions to the Shareholder, returns of capital and by losses allocated to the Shareholder. Contributions of property by a Shareholder, if any, or distributions of property to a Shareholder, if any, are valued at fair market value, net of liabilities. The Fund does not currently anticipate that any contributions or distributions of property will be made. Certain additional adjustments to capital accounts will be made if necessary to account for the effects of non-recourse debt incurred by the Fund, if any, or contributions of property, if any, to the Fund. See Tax Aspects - Allocations. For any year, profits and losses are allocated in accordance with Articles 4 and 7 of the LLC Agreement. In general, profits and losses in any year are allocated 85% to Investors and 15% to the Manager. The primary exception to this treatment is that all items of expense, loss, deduction and credit attributable to the expenditure of Investor's Capital Contributions are allocated 99% to Investors and 1% to the Manager.
Capital Accounts and Allocations. A capital account will be established for each Unit in each Series and the General Partner with respect to each Series. The balance of each capital account will be the amount contributed to a Series in respect of a Unit or by the General Partner increased by (i) the amount of all net income and gains allocated to such Unit or the General Partner and decreased by (ii) the amount of all net losses allocated to such Unit or the General Partner. It is intended that the capital accounts will be maintained at all times in accordance with Section 704 of the Internal Revenue Code of 1986, as amended, and applicable Treasury regulations thereunder.
Capital Accounts and Allocations. A capital account will be established for each Partner. The initial balance of each Partner’s capital account will be the amount of a Partner’s initial capital contribution to a Series less, in the case of a Limited Partner, the amount of offering expenses and selling commissions initially allocable to the Limited Partner’s Units, if any. As of the close of business (as determined by the General Partner) on the last day of each calendar month (“Determination Date”) during each fiscal year of a Series, the following determinations and allocations will be made subsequently with respect to each Series:
Capital Accounts and Allocations. (a) The Partnership shall maintain a separate capital account (a “Capital Account”) for each Partner in accordance with the principles and requirements set forth in Section 704(b) of the Code and the Regulations. The Capital Account of each Partner shall be credited with such Partner’s capital contributions to the Partnership, and all Profits allocated to such Partner pursuant to Section 16(b), and shall be increased by the amount of any Partnership liabilities that are assumed by such Partner or secured by any Partnership property distributed to such Partner; and the Capital Account of each Partner shall be debited with all Losses allocated to such Partner pursuant to Section 16(b), any items of loss or deduction of the Partnership specially allocated to such Partner pursuant to Section 16(b), and all cash and the fair market value of any property (net of liabilities assumed by such Partner and the liabilities to which such property is subject) distributed by the Partnership to such Partner, and shall be decreased by the amount of any liabilities of such Partner assumed by the Partnership or which are secured by any property contributed by such Partner to the Partnership. Notwithstanding anything to the contrary contained in this Agreement, the Capital Accounts of the Partners shall be adjusted and maintained in accordance with the rules of Regulations Section 1.704-1(b)(2)(iv), as the same may be amended or revised. No Partner shall be required to restore any negative balance in its Capital Account except as may be required by applicable law. In the event of any transfer of any interest in accordance with the terms of this Agreement, the transferee shall succeed to the Capital Account (including prior capital contributions and distributions of investment proceeds) of the transferor to the extent it relates to the transferred interest.
