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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
ncurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
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
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
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
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
Entities connected to both Luxembourg and Application of Basis

United Kingdom
LOCATION
United States
LOCATION
Malaysia
LOCATION
New York
LOCATION
George W. Bush
PERSONCayman
LOCATIONKeogh
ORGANIZATION
University of Oxford
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
Ghislaine Maxwell
PERSON
U.S. Treasury
ORGANIZATIONthe American Stock Exchange
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
Wilbur Ross
PERSON
JPMorgan Chase
ORGANIZATION
Dalton School
ORGANIZATION
Tokyo
LOCATIONthe U.S. Investment Advisers Act
ORGANIZATION
Mohammed bin Salman
PERSON
the Cayman Islands
LOCATION