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SOF III - 1081 Southern Financial LLC the Master Fund purchase and sell stocks and securities. The Onshore Feeder Fund, the Offshore Feeder Fund or their respective Investors may be required to file tax
Islands law, there are no taxes on income or gains and distributions made by the Offshore Feeder Fund will not be subject to withholding tax in the Cayman Islands. The Cayman Islands currently imposes stamp duty on certain categories of documents; however the contemplated operations of the Offshore Fe
RS OF THE MASTER FUND The Master Fund Board of Directors generally meets twice a year to review and assess the investment policy and performance of the Master Fund and generally to supervise the conduct of its affairs. The directors and their business experience are as follows: Sander Gerber. Biographical inf
in the Cayman Islands. He is the service line leader and has overall responsibility for advising on the establishment and ongoing administration of Cayman Islands companies and funds, including acting as a director of Cayman Islands funds and other client companies. He is a qualified Chartered Account
There is no assurance that the Fund will be able to obtain from any company that is a PFIC the necessary information, on an annual basis, to permit the Master Fund to make an election to treat any such PFIC as a QEF. The Fund also may have the option to elect to mark stock in a PFIC to market at the end of ever
Fund carried on outside the Cayman Islands. The Fund is a regulated mutual fund for the purposes of the Mutual Funds Law and is registered with the Cayman Islands Monetary Authority (-MA") pursuant to section 4(3) of that law. This offering memorandum has been filed with CIMA. Such registration does n
investors" and "qualified purchasers" under the U.S. federal securities laws. Millennium International primarily invests its capital indirectly in the Master Fund, through its investment in Millennium Offshore Intermediate, L.P. ("Millennium Offshore Intermediate"), a Cayman Islands exempted limited partnersh
rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)
investors" and "qualified purchasers" under the U.S. federal securities laws. Millennium International primarily invests its capital indirectly in the Master Fund, through its investment in Millennium Offshore Intermediate, •. ("Millennium Offshore Intermediate"), a Cayman Islands exempted limited partnershi
rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)
Entities connected to both the Master Fund and Cayman

United States
LOCATION
the Cayman Islands
LOCATION
Ghislaine Maxwell
PERSON
Jeffrey Epstein
PERSON
Alan Dershowitz
PERSON
U.S. Treasury
ORGANIZATION
George W. Bush
PERSON
United Kingdom
LOCATION
New York
LOCATION
Cayman Islands
LOCATIONKeogh
ORGANIZATION
Luxembourg
LOCATION
JPMorgan Chase
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
Paul Barrett
PERSONErnst & Young LLP
ORGANIZATION
New York State
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONMarkel
ORGANIZATION