EFTA01359078.pdf

and file, a Federal information tax return in compliance with Section 6031 of the Code and any required state and local income tax and information returns for each tax year of the Company. The Company shall prepare and mail, or cause its accountants to prepare and mail, to each Member a report setting forth in sufficient detail that information which will enable such Member or former Member (or such Member's legal representative) to prepare such Member's federal, state and local tax returns in accordance with the laws, rules and regulations then prevailing. Each Member hereby agrees to file such Member's individual income tax return in a manner consistent with the manner by which the Company has filed its tax return and the report provided by the Company to that Member. Due to the confidential nature of the tax information provided herein, each Non-Managing Member agrees that it shall use only a tax return preparer listed on Schedule D hereof or as otherwise approved in writing by the Managing Member. f. Tax Matters Partner. The Members intend that the Company be treated as a partnership for Federal income tax purposes. The Managing Member shall have the full powers and responsibilities as (i) the "tax matters partner" within the meaning of Section 6231(aX7) of the Internal Revenue Code of 1986, as amended, and (ii) the "partnership representative" within the meaning of Section 6223(a) of the Internal Revenue Code of 1986, as amended and as modified by the Bipartisan Budget Act of 2015. g. Computations. All computations of Fund Incentive Performance, Fund Incentive P&L, Profit Share and Capital Accounts hereunder shall be made based upon amounts determined in the financial accounting records of the Firm and the Fund Managers. Except as otherwise set forth herein, all items of expense shall be determined using the accrual method. All items of income shall be determined using the cash and/or accrual method as the Managing Member shall reasonably determine. In this regard, incentive fees from Styx DOC ID • 2506146812 41 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0047084 CONFIDENTIAL SDNY_GM_00193268 EFTA01359078