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ly in New York, New York and Greenwich, Connecticut. Millennium's primary international office locations are in London, U.K., Singapore, Hong Kong, Tokyo, Japan and Geneva, Switzerland. Millennium has a number of other office locations as well. Corporate Services Pursuant to the Administration Agree
76 CONFIDENTIAL UBSTERRAMAR00004079 EFTA00239411 FOR EXISTING INVESTOR USE ONLY Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
s or acquire other clients. ML281817-MAXWELL 1-68 CONFIDENTIAL UBSTERRAMAR00002398 EFTA00237954 Millennium Capital Management (Asia) Limited, Tokyo branch, a subsidiary of an affiliate of Millennium Management, is licensed under the Japanese Financial Instruments and Exchange Law, exercises the
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
ing a personal loss). The ownership structure of MCP UK may change from time to time without notice. Each of MCM Singapore, MCM FIK, and MCM Asia's Tokyo Branch (collectively, the "Asia Entities") is owned by Millennium International Management. The capital to establish, capitalize and maintain the A
itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
business or acquire other clients. -MAXWELL 1-68 CONFIDENTIAL UBSTERRAMAR00001345 EFTA00236991 Millennium Capital Management (Asia) Limited, Tokyo branch, a subsidiary of an affiliate of Millennium Management, is licensed under the Japanese Financial Instruments and Exchange Law, exercises the
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
ing a personal loss). The ownership structure of MCP UK may change from time to time without notice. Each of MCM Singapore, MCM FIK, and MCM Asia's Tokyo Branch (collectively, the "Asia Entities") is owned by Millennium International Management. The capital to establish, capitalize and maintain the A
itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
Entities connected to both Tokyo and Cayman Islands Tax Matters

United States
LOCATION
George W. Bush
PERSON
Marc Rich
PERSON
New York
LOCATION
Ghislaine Maxwell
PERSON
Department of Justice
ORGANIZATION
United Kingdom
LOCATION
Samantha Power
PERSON
Dallas
LOCATION
Malaysia
LOCATION
New York State
LOCATION
Wilbur Ross
PERSONthe State of New York
LOCATIONAkasaka
PERSON
U.S. Treasury
ORGANIZATION
Federal Reserve
ORGANIZATION
Millennium
ORGANIZATIONCayman
LOCATION
Mohammed bin Salman
PERSON
JPMorgan Chase
ORGANIZATION