Epstein Secrets

ures, premiums for general partner liability insurance and risk- specific insurance and "key-man" life insurance on certain personnel (including Mr. Englander, the managing member of the General Partner), and other administrative and operating expenses. Expenses that are allocable to the Feeder Funds gene

re not appropriate or not optimal (for tax or other reasons) for direct or indirect investors in the Master Partnership. Millennium, including Mr. Englander, may, and typically does, have a disproportionate investment in one or more of the Feeder Funds and may, therefore, benefit from any benefit derive

t present, no direct taxation in the Cayman Islands and interest, dividends and gains payable to the Master Partnership will be received free of all Cayman Islands taxes. The Master Partnership is registered as an "exempted limited partnership" pursuant to the Exempted Limited Partnership Law (as amend

ures, premiums for general partner liability insurance and risk- specific insurance and "key-man" life insurance on certain personnel (including Mr. Englander, the managing member of the General Partner), and other administrative and operating expenses. Expenses that are allocable to the Feeder Funds gene

re not appropriate or not optimal (for tax or other reasons) for direct or indirect investors in the Master Partnership. Millennium, including Mr. Englander, may, and typically does, have a disproportionate investment in one or more of the Feeder Funds and may, therefore, benefit from any benefit derive

t present, no direct taxation in the Cayman Islands and interest, dividends and gains payable to the Master Partnership will be received free of all Cayman Islands taxes. The Master Partnership is registered as an "exempted limited partnership" pursuant to the Exempted Limited Partnership Law (as amend

e deemed to be made on a first-in first-out basis absent specific instructions to the contrary from the investor. In the event of the death of Mr. Englander, the death benefits distributable to the Master Partnership from "keyman" life insurance upon Mr. Englander's life will be deemed to be assets of t

(ii) a police officer of the rank of constable or higher, or the Financial Reporting Authority, pursuant to the Terrorism Law (2018 Revision) of the Cayman Islands, if the disclosure relates to involvement with terrorism or terrorist financing and property. Such a report will not be treated as a breach

surance, casualty and property, cyber liability and other risk-specific insurance, and "key-man" life insurance on certain personnel (including Mr. Englander); financing costs, exchange fees and expenses, brokerage fees and expenses, expenses relating to short sales, clearing and settlement charges, cust

ns require the Master Partnership to, amongst other things, (i) register with the Service; (ii) register with the Cayman TIA, and thereby notify the Cayman TIA of its status as a "Reporting Financial Institution"; (iii) adopt and implement written policies and procedures setting out how it will address

drawal dates that occurred prior to the occurrence of the Trigger Event will be paid during the Transition Period. In the event of the death of Mr. Englander, the death benefits distributable to Millennium USA or the Master Partnership from "keyman" life insurance upon Mr. Englander's life will be deemed

rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)

drawal dates that occurred prior to the occurrence of the Trigger Event will be paid during the Transition Period. In the event of the death of Mr. Englander, the death benefits distributable to Millennium USA or the Master Partnership from "keyman" life insurance upon Mr. Englander's life will be deemed

rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)