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zation. Plan Assets Rules means Section 3(42) of ERISA and any rules and regulations thereunder, together with any plan assets regulation issued by the U.S. Department of Labor under ERISA, including 29 C.F.R. § 2510.3-101, as amended. Positive Basis means, with respect to any Member and as of any time of calculation, the
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
zation. Plan Assets Rules means Section 3(42) of ERISA and any rules and regulations thereunder, together with any plan assets regulation issued by the U.S. Department of Labor under ERISA, including 29 C.F.R. § 2510.3-101, as amended. Positive Basis means, with respect to any Member and as of any time of calculation, the
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
zation. Plan Assets Rules means Section 3(42) of ERISA and any rules and regulations thereunder, together with any plan assets regulation issued by the U.S. Department of Labor under ERISA, including 29 C.F.R. § 2510.3-101, as amended. Positive Basis means, with respect to any Member and as of any time of calculation, the
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 the U.S. Department of Labor and Cayman Islands Tax Matters

United States
LOCATION
Department of Justice
ORGANIZATION
New York
LOCATIONCayman
LOCATION
Ghislaine Maxwell
PERSONKeogh
ORGANIZATIONErnst & Young LLP
ORGANIZATION
U.S. Treasury
ORGANIZATION
Millennium
ORGANIZATION
Marc Rich
PERSONthe Securities and Exchange Commission
ORGANIZATION
United Kingdom
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
JPMorgan Chase
ORGANIZATIONRelated-Party Transactions
ORGANIZATION
Tokyo
LOCATION
Federal Reserve
ORGANIZATION
Mohammed bin Salman
PERSONthe Non-USD Shares
ORGANIZATION
England
LOCATION