EFTA00605187Set 9
2016-03-2318p5,764w
Member shall be determined and maintained
in accordance with the rules of Treasury Regulation Section 1.704-1 (bX2Xiv) and, to the extent consistent
therewith, each Member's Capital Account shall ... Members' Capital Accounts are
adjusted because of any of the events described in Treasury Regulation Section 1.704-I (bX2)(ivXf), subsequent
allocations of federal income tax items with respect
https://www.justice.gov/epstein/files/DataSet%209/EFTA00605187.pdf
EFTA00312828Set 9
2012-10-1924p8,275w
distributed by the Company, the adjustments to
Capital Accounts required by Treasury Regulation Section 1.704-1(bX2XivXd), (e),
(f) and (g) and Section 1.704-1(b)(4)(I) shall ... Accounts under Code Section 705(aX2XB) or are treated as
such expenditures under Treasury Regulation Section 1.704-1(bX2XivXi).
"Nonrecourse Deductions" shall have the meaning set forth in Treasury Regulation ... distributed by the Company, the adjustments to
Capital Accounts required by Treasury Regulation Section 1.704-1(bX2XivXd), (e),
(f) and (g) and Section 1.704-1(bX4XI) shall be made
https://www.justice.gov/epstein/files/DataSet%209/EFTA00312828.pdf
EFTA01093471Set 9
38p18,496w
Members shall be adjusted and
maintained in accordance with the rules of Treasury Regulations Section 1.704-1(b)(2)(v), as the
same may be amended or revised ... Member Nonrecourse Debt
Minimum Gain (determined in accordance with the principles of Treasury Regulations
Sections 1.704-2(d) and 1.704-2(0) during any Company taxable year, the Members shall ... their respective shares of such net decrease during such year, determined pursuant
to Treasury Regulations Sections 1.704-2® and 1.704-2(i)(5). The items to be so allocated shall
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093471.pdf
EFTA02435864Set 11
2009-05-0134p13,410w
each Member in accordance with Section 704(b) of the Code
and Treasury Regulations Sections 1.704-1(b) and 1.704-2. On the Closing, the initial Capital
Account balance ... liquidation of such Member's Interest to the
extent required pursuant to Treasury Regulations Section 1.704-1(bX2)(ivXm).
(g) Except as otherwise provided in this Agreement, whenever ... Agreement relating to the maintenance of Capital
Accounts are intended to comply with Treasury Regulations Section 1.704-1(b), and shall be
interpreted and applied in a manner consistent with
https://www.justice.gov/epstein/files/DataSet%2011/EFTA02435864.pdf
EFTA01093509Set 9
40p19,567w
CONFIDENTIAL DRAFT
SOLELY FOR INTENDED RECIPIENT
maintained in accordance with the rules of Treasury Regulations Section 1.704-1(b)(2)(iv), as the
same may be amended or revised ... Partner Nonrecourse Debt
Minimum Gain (determined in accordance with the principles of Treasury Regulations
Sections 1.704-2(d) and 1.704-2(0) during any Partnership taxable year, the Partners shall ... their respective shares of such net decrease during such year, determined
pursuant to Treasury Regulations Sections 1.704-2(g) and 1.704-20)(5). The items to be so allocated
shall
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093509.pdf