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he income is sourced. Millennium Management and its affiliates operate throughout the world in various jurisdictions, including the United Kingdom, Luxembourg, Hong Kong, Japan, Singapore and Switzerland. Millennium Management and its affiliates generally endeavor to conduct such activities in a manner suc
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
h source as discussed above. Luxembourg Taxation Millennium USA and the Master Partnership have been separately advised as follows with respect to Luxembourg taxation. Classification of the Master Partnership and Millennium USA as Foreign Taxpayers. For Luxembourg tax purposes, entities which do not have
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
h source as discussed above. Luxembourg Taxation Millennium USA and the Master Partnership have been separately advised as follows with respect to Luxembourg taxation. Classification of the Master Partnership and Millennium USA as Foreign Taxpayers. For Luxembourg tax purposes, entities which do not have
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
Entities connected to both Luxembourg and Allocation of Profits and Losses

United Kingdom
LOCATION
United States
LOCATION
Malaysia
LOCATION
New York
LOCATION
George W. Bush
PERSONCayman
LOCATIONLeon Black
PERSONKeogh
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
University of Oxford
ORGANIZATION
Ghislaine Maxwell
PERSON
the Internal Revenue Service
ORGANIZATION
U.S. Treasury
ORGANIZATIONthe American Stock Exchange
ORGANIZATIONReliance
ORGANIZATION
Wilbur Ross
PERSON
JPMorgan Chase
ORGANIZATION
Dalton School
ORGANIZATIONthe Offered Interests
ORGANIZATIONAccounting Period
ORGANIZATION