Corporate/trust instrument (EFTA01391823)

GLDUS142 Ironsides Asset Mgmt (A) is not a partnership, grantor trust, or Subchapter S corporation for United States federal income tax purposes: or (B) is a partnership, grantor trust, or Subchapter S corporation for United States federal income tax purposes, and (x) at no time during the term of the Partnership will 65% or more of the value of any beneficial owner's direct or indirect interest in the Sole Owner be attributable to the Sole Owner's interests in the Partnership, (y) less