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debt or obligation is attributable. Term; Dissolution. Millennium USA will continue until the earlier of (i) an event of withdrawal (as defined in the Delaware Revised Uniform Limited Partnership Act, as amended (the "Act")) of Millennium Management; provided that Millennium USA will not be dissolved nor r
ncurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
debt or obligation is attributable. Term; Dissolution. Millennium USA will continue until the earlier of (i) an event of withdrawal (as defined in the Delaware Revised Uniform Limited Partnership Act, as amended (the "Act")) of Millennium Management; provided that Millennium USA will not be dissolved nor r
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
debt or obligation is attributable. Term; Dissolution. Millennium USA will continue until the earlier of (i) an event of withdrawal (as defined in the Delaware Revised Uniform Limited Partnership Act, as amended (the "Act")) of Millennium Management; provided that Millennium USA will not be dissolved nor r
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
Entities connected to both the Delaware and Application of Basis

New York
LOCATION
the Cayman Islands
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
U.S. Treasury
ORGANIZATION
United States
LOCATION
the Internal Revenue Service
ORGANIZATIONthe Master Fund
ORGANIZATIONTrigger Event
ORGANIZATIONAccounting Period
ORGANIZATIONReliance
ORGANIZATION
Millennium
ORGANIZATIONOptions and Special Allocations
ORGANIZATION
Luxembourg
LOCATIONMunger, Tolles & Olson LLP
ORGANIZATION
Occidental College
ORGANIZATION
Mohammed bin Salman
PERSONErnst & Young LLP
ORGANIZATION
United Kingdom
LOCATIONMillennium USA's
LOCATION
England
LOCATION