6
Shared Docs
6
Same-Page
8 / 6
Mentions
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
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
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
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
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
00239344 FOR EXISTING INVESTOR USE ONLY 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 Caym
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
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
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
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
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
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
Entities connected to both England and Cayman Islands Tax Matters

United States
LOCATION
Ghislaine Maxwell
PERSON
Marc Rich
PERSON
New York
LOCATION
JPMorgan Chase
ORGANIZATION
George W. Bush
PERSON
New York State
LOCATION
United Kingdom
LOCATION
Millennium
ORGANIZATION
Mohammed bin Salman
PERSONMillennium USA LP
ORGANIZATION
Tokyo
LOCATION
Federal Reserve
ORGANIZATION
Department of Justice
ORGANIZATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Samantha Power
PERSON