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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
ds except in furtherance of the business of the 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 wi
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
the Cayman Islands Pursuant to recent amendments to the Mutual Funds 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 regist
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
the Cayman Islands Pursuant to recent amendments to the Mutual Funds 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 regist
Entities connected to both the Master Fund and the Mutual Funds Law

United States
LOCATION
New York
LOCATION
the Cayman Islands
LOCATIONCayman
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Mohammed bin Salman
PERSON
New York State
LOCATIONCayman Islands Tax Matters
ORGANIZATION
England
LOCATIONErnst & Young LLP
ORGANIZATIONKeogh
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Millennium
ORGANIZATIONthe Delaware
ORGANIZATIONthe Commodity Futures Trading Commission
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATIONAccounting Period
ORGANIZATION
Tokyo
LOCATION