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SRZ's concurrent representation of such parties in such circumstances. Millennium USA's Independent Public Accountants Millennium USA has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. DOC ID- 29147063.5 1-66 CONFIDENTIAL UBSTERRAMAR0000399
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
scal year-end of the Master Partnership is December 31. The Master Partnership's Independent Public Accountants The Master Partnership has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. 11-82 CONFIDENTIAL UBSTERRAMAR00004085 EFTA00239417 F
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
SRZ's concurrent representation of such parties in such circumstances. Millennium USA's Independent Public Accountants Millennium USA has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. ML281817-MAXWELL I40 CONFIDENTIAL UBSTERRAMAR00002410
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
II-63 CONFIDENTIAL UBSTERRAMAR00002479 EFTA00238035 The Master Partnership's Independent Public Accountants The Master Partnership has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. ML281817-MAXWELL II-64 CONFIDENTIAL UBSTERRAMAR00002480
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
SRZ's concurrent representation of such parties in such circumstances. Millennium USA's Independent Public Accountants Millennium USA has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. -MAXWELL I-80 CONFIDENTIAL UBSTERRAMAR00001357 EFTA002
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
II-63 CONFIDENTIAL UBSTERRAMAR00001426 EFTA00237072 The Master Partnership's Independent Public Accountants The Master Partnership has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. =MAXWELL II-64 CONFIDENTIAL UBSTERRAMAR00001427 EFTA00
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 Ernst & Young LLP and Cayman Islands Tax Matters
Cayman
LOCATION
New York
LOCATION
United States
LOCATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
the Cayman Islands
LOCATION
JPMorgan Chase
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
United Kingdom
LOCATION
Ghislaine Maxwell
PERSON
Mohammed bin Salman
PERSON
England
LOCATIONthe Mutual Funds Law
ORGANIZATION
New York State
LOCATION
U.S. Treasury
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Fannie Mae
ORGANIZATION
Marc Rich
PERSON
UBS AG
ORGANIZATION
Federal Reserve
ORGANIZATION