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		| @@ -114,6 +114,19 @@ This Agreement specifically implements: | ||||
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| * **Operational Standards**: Uniform operational standards, electronic recordkeeping requirements, and compliance protocols ensuring consistent business operations while maintaining series isolation and regulatory compliance. | ||||
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| ### Tax and Regulatory Considerations | ||||
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| This amendment and restatement has been structured with careful consideration of: | ||||
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| * Federal, state, and local tax implications for the Company and its series; | ||||
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| * Securities law compliance for current and future capital raising activities; | ||||
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| * Regulatory requirements across all jurisdictions where the Company and its series operate; and | ||||
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| * Preservation of favorable tax treatment for all existing and prospective members. | ||||
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| ## Section 1.4 - Effect of Amendment and Restatement | ||||
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| Upon execution of this Agreement: | ||||
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