EFTA01389675.txt Text dataset_10 View on DOJ

This document outlines the special and tax allocation methods within a partnership agreement, ensuring compliance with relevant sections of the Internal Revenue Code. It details how income, gains, losses, and expenses are distributed among partners, with the General Partner having the authority to modify allocations to reflect economic interests more accurately.

Subject

EverWatch Financial Proprietary and Confidential

Sender

—

Recipients

—

Document ID

SDNY_GM_00240222 DB-SDNY-0094038

Date

—

"The General Partner is authorized to modify the allocations otherwise provided for under Article 8 and this Appendix II including by specially allocating items of gross income, gain, loss, or expense among the Partners, if advised by the Partnership's tax advisors that such modifications or such special allocations will cause the Capital Accounts of the Partners to reflect more closely the Partners' relative economic interests in the Partnership as set forth in Article 7 and Article 10."

"Except as otherwise provided in the Agreement or this Appendix II or as required by Section 704 of the Code, for tax purposes, all items of income, gain, loss, deduction or credit shall be allocated to the Partners in the same manner as are Net Gains and Net Losses and other items allocated pursuant to Article 8 and the other provisions of this Appendix II; provided however, that if the Carrying Value of any property of the Partnership differs from its adjusted basis for tax purposes, then items of income, gain, loss, deduction or credit related to such property for tax purposes shall be allocated among the Partners so as to take account of the variation between the adjusted basis of the property for tax purposes and its Carrying Value in the manner provided for under Section 704(c) of the Code."

• Compliance with Section 706(d) of the Code
• Compliance with Section 704 of the Code

Financial transactions/money flowLegal matters/litigationBusiness dealings

EverWatch FinancialAccess Secondary Opportuniticc IV (U.S.), L.P.Partnership

Tone

Professional

Purpose

To outline special allocations and tax allocations within a partnership agreement.

Significance

This document details the financial and tax-related aspects of a partnership agreement, specifically focusing on how income, gains, losses, and expenses are allocated among partners.

File Name

EFTA01389675.txt

Dataset

dataset_10

Type

Text

Model

gemini-2.0-flash-001

Processed

2026-02-07T18:42:45.220539

DOJ Source

View on DOJ