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ership's Independent Public Accountants: ML281817-MAXWELL In 2005, Millennium entered into a settlement with the SEC and the Attorney General of the State of New York pursuant to which the Millennium parties to the settlement neither admitted nor denied any wrongdoing but agreed to make certain payments as disgo
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
2005, the General Partner, Mr. Englander and certain other Millennium officers and affiliates entered into settlements with the Attorney General of the State of New York and the SEC relating to allegations that the respondents had improperly engaged in activities related to "market timing" of investments in mutual f
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
Partnership's Independent Public Accountants: MM -MAXWELL In 2005, Millennium entered into a settlement with the SEC and the Attorney General of the State of New York pursuant to which the Millennium parties to the settlement neither admitted nor denied any wrongdoing but agreed to make certain payments as disgo
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
2005, the General Partner, Mr. Englander and certain other Millennium officers and affiliates entered into settlements with the Attorney General of the State of New York and the SEC relating to allegations that the respondents had improperly engaged in activities related to "market timing" of investments in mutual f
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 State of New York and Cayman Islands Tax Matters

JPMorgan Chase
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
Ghislaine Maxwell
PERSON
United States
LOCATION
Federal Reserve
ORGANIZATION
George W. Bush
PERSON
New York
LOCATION
Samantha Power
PERSON
New York State
LOCATIONthe Securities and Exchange Commission
ORGANIZATION
Department of Justice
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
Marc Rich
PERSON
Internal Revenue Service
ORGANIZATION
Tokyo
LOCATION
Wilbur Ross
PERSONKeogh
ORGANIZATION
U.S. Treasury
ORGANIZATIONCayman
LOCATION
UBS AG
ORGANIZATION