Extract to table

Based on the analysis set forth herein, we conclude that the § 704(c) built-in gain and loss accounts maintained by the Legacy Offshore Vehicles with respect to contributed properties carry over to the Master Fund, and the Master Fund is required to continue tracking and allocating those BIG/BIL accounts in accordance with § 704(c) principles

• Pre-existing "inner" § 704(c) layers at the Legacy Offshore Vehicle level, including any reverse § 704(c) layers arising from partnership revaluations, must be addressed in the tiered partnership context pursuant to Treas

This outer layer represents the economically significant BIG that must be tracked and allocated by the Master Fund going forward

Additionally, as noted above, pre-existing "inner" § 704(c) layers at the Legacy Offshore Vehicle level (reflecting historic contributions by LPs or revaluation events) must be addressed in the tiered partnership context, as discussed in Section V

The § 704(c) BIG and BIL accounts maintained by the Legacy Offshore Vehicles carry over and must be preserved in the Master Fund upon contribution of the portfolio company interests under IRC § 721(a)

The election must be properly documented in the Master Fund's limited partnership agreement