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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
dments to the Fund Agreement Tax Consequences The Fund is a regulated mutual fund for the purposes of the Mutual Funds Law and is registered with the Cayman Islands Monetary Authority ("CIMA") pursuant to section 4(3) of that law. This offering memorandum has been filed with CIMA. Such registration does not imply that CIMA or any
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
ds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for registration pursuant to the Mutual Funds Law. The registration process and the consequenc
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
ds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for registration pursuant to the Mutual Funds Law. The registration process and the consequenc
Entities connected to both the Master Fund and the Cayman Islands Monetary Authority

United States
LOCATION
the Cayman Islands
LOCATIONCayman
LOCATION
New York
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATIONReliance
ORGANIZATION
Mohammed bin Salman
PERSON
New York State
LOCATION
JPMorgan Chase
ORGANIZATIONKeogh
ORGANIZATION
United Kingdom
LOCATION
Millennium
ORGANIZATION
England
LOCATIONMillennium USA LP
ORGANIZATION
Occidental College
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATION
Tokyo
LOCATIONthe Delaware
ORGANIZATION