Extract to table

1 — Defined Terms All capitalized terms used but not otherwise defined in this Amendment shall have the respective meanings ascribed to such terms in the Partnership Agreement

(b) In the event of any conflict or inconsistency between the terms and provisions of this Amendment and the terms and provisions of the Partnership Agreement (as in effect immediately prior to the effectiveness of this Amendment), the terms and provisions of this Amendment shall control and prevail

(d) The terms "include," "includes," and "including" shall be deemed to be followed by the words "without limitation

The Step 4 Contributions constitute tax-free contributions of property to the Consolidated Master Fund in exchange for partnership interests under IRC § 721(a), and no gain or loss shall be recognized by Fund V-A Cayman, Fund V-B Lux, or any of their respective partners as a result of such contributions

The Consolidated Master Fund's holding period in such assets shall include the holding period of the contributing partnerships under IRC § 1223(2)

Built-in gain and loss accounts under IRC § 704(c) applicable to the portfolio company assets held by the Legacy Offshore Vehicles shall carry over to the Consolidated Master Fund and shall be maintained and tracked by the Consolidated Master Fund using the remedial allocation method described in Treasury Regulations § 1