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and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.
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
g and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.
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
g and Investor Relations Department with a primary focus on building and developing new and current investor relationships. Mr. Novogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London.
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 Fortress Investment Group and Cayman Islands Tax Matters

United States
LOCATION
England
LOCATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATIONCayman
LOCATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
Mohammed bin Salman
PERSONthe Cayman Islands Monetary Authority
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSON
New York
LOCATIONLehman
ORGANIZATIONDavid Nolan
PERSONApplied Development
ORGANIZATION
Marc Rich
PERSONJohn Novogratz
PERSON