for U.S. federal income tax purposes. The following discussion is based on the assumption that the Fund will not be treated as a “publicly traded partnership.” Treatment of U.S. Partners and Non-US. Partners - The discussion below addresses separately certain U.S. federal income tax matters relevant to U.S. Partners and Non-U.S. Partners. For purposes of this discussion, the term “U.S. person” generally means any U.S. citizen or resident individual, any corporation, limited liability company, or partnership organized under U.S. law, any estate (other than an estate the income of which, from sources outside the U.S. that is not effectively connected with a trade or business within the U.S., is not includible in its gross income for U.S. federal income tax purposes), and any trust if a court within the U.S. is able to exercise primary supervision over the administration of the trust and one or more U.S. persons have the authority to control all substantial decisions of the trust. The term “U.S. Partner” means any partner that is a U.S. person and, unless the context otherwise requires, includes any U.S. person that holds an equity interest in the Fund through one or more partnerships or other entities treated as transparent for U.S. federal income tax purposes. The term “Non-U.S. Partner” means a Partner that is not a U.S. person. Taxation of Fund Operations Generally - As a partnership, the Fund will not pay U.S. federal income taxes, but each U.S. Partner will be required to report that Partner’s distributive share (whether or not distributed) of the Fund’s income, gains, losses, deductions and credits of the character specified in Section 702 of the Code. It is possible that the U.S. Partners could incur U.S. federal income tax liabilities without receiving from the Fund sufficient distributions to defray such tax liabilities. The Fund’s taxable year will be the calendar year, or such other period as required by the Code. Tax information will be delivered to all Pa