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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
that exemption. U.S. Investment Advisers Act None of the General Partner, the Manager and their affiliates is currently registered of 1940 under the U.S. Investment Advisers Act of 1940, as amended (the "Advisers Act). However, either or both of the Manager and the General Partner may be required to become registered under
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
act, and they therefore are not subject to registration thereunder. The General Partner is registered as an investment adviser with the SEC under the U.S. Investment Advisers Act of 1940, as amended. Certain affiliates of the General Partner and certain Portfolio Managers are "Relying Advisers" who rely on the General Partn
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
act, and they therefore are not subject to registration thereunder. The General Partner is registered as an investment adviser with the SEC under the U.S. Investment Advisers Act of 1940, as amended. Certain affiliates of the General Partner and certain Portfolio Managers are "Relying Advisers" who rely on the General Partn
Entities connected to both the Master Fund and the U.S. Investment Advisers Act

United States
LOCATION
the Cayman Islands
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONCayman
LOCATIONReliance
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
New York
LOCATIONKeogh
ORGANIZATION
Luxembourg
LOCATION
Occidental College
ORGANIZATION
United Kingdom
LOCATIONthe Delaware
ORGANIZATIONU.S. Limited
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONAccounting Period
ORGANIZATIONthe Limited Partner's
ORGANIZATIONthe Incentive Allocation
ORGANIZATIONU.S. Persons
ORGANIZATIONInvestment
ORGANIZATION
New York State
LOCATION