Illegal Activity
none
Blackmail
none
Date
2017-12-31
Document Type
Limited Partnership Agreement
Model
gemini-2.0-flash-001
Processed
2026-02-07T18:43
Summary
This document is an amended and ratified limited partnership agreement outlining the responsibilities of the general and limited partners, particularly regarding tax compliance and audit procedures. It details the designation of the General Partner as the partnership representative and the partners' obligations to provide necessary information for tax purposes, including FATCA compliance.
Metadata
- Subject
- Amended and Ratified Limited Partnership Agreement
- Sender
- —
- Recipients
- —
- Document ID
- DB-SDNY-0039609
- Date
- 2017-12-31
Relationships 3
| Entity 1 | Relationship | Entity 2 | Description |
|---|---|---|---|
| General Partner | Legal | Partnership | General Partner is designated the partnership representative. |
| Partners | Financial | Partnership | Partners are responsible for imputed underpayment imposed on the Partnership. |
| Limited Partner | Financial | General Partner | Limited Partner bears the costs of actions taken by the General Partner. |
Notable Quotes 3
"the General Partner shall be designated the `partnership representative" within the meaning of Section 6223(a) of the Code"
"the Partners consent to the election set forth in Section 6226(a) of the Code and agree to take any action, and furnish the General Partner with any information necessary, to give effect to such election if the General Partner decides to make such election"
"Each Partner agrees to promptly provide the General Partner such information regarding the Partner and its beneficial owners and forms as the General Partner requests so that the Partnership may avoid any adverse consequences under FATCA."
Financial Information
Transactions:
- Imputed underpayment imposed on the Partnership pursuant to Code Section 6232
- Subsequent reduction in distributions otherwise payable to such Partner plus interest on such amount calculated at the Prime Rate plus 2%
Legal Compliance
- Compliance with Section 1101 of the BBA (Bipartisan Budget Act)
- Compliance with Code Section 6223(a) and 6226(a)
- Compliance with Code Section 6232
- Compliance with applicable tax laws
- Compliance with FATCA
Raw Analysis JSON
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Themes
Financial transactions/money flowLegal matters/litigationBusiness dealings
Organizations 4
Pacific Life Insurance CoOlendoncr Accent Secondary Opportunidim IV (U.S.)* L.P.U.S. Internal Revenue ServiceU.S. Treasury
Locations 1
U.S.
Text Analysis
- Tone
- Legal
- Purpose
- To amend and ratify a limited partnership agreement, specifically addressing tax-related responsibilities and obligations of the partners.
- Significance
- This document outlines the financial and legal responsibilities of the partners within the limited partnership, particularly concerning tax audits and compliance with FATCA.
File Info
- File Name
- EFTA01354971.txt
- Dataset
- dataset_10
- Type
- Text
- Model
- gemini-2.0-flash-001
- Processed
- 2026-02-07T18:43:53.513486
- DOJ Source
- View on DOJ