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rvices; and (v) year-end support services with respect to Millennium USA's audit and tax processes, as may be required. (See "The Administrator.") Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a
cording of 1-12 CONFIDENTIAL UBSTERRAMAR00003943 EFTA00239275 FOR EXISTING INVESTOR USE ONLY Taxation: ERISA and Other Tax Exempt Entities: Anti-Money Laundering Considerations: DOC ID- 29147063.5 transactions and the reconciliation of cash, positions and transactions between Millennium USA's and the Maste
Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a
lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its
Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a
lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its
Entities connected to both Schulte Roth & Zabel LLP and Anti-Money Laundering

United States
LOCATION
Jeffrey Epstein
PERSONthe District of Columbia
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONCayman
LOCATIONKeogh
ORGANIZATION
Paul Volcker
PERSONthe U.S. Investment Company Act
ORGANIZATIONMillennium Partners
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATION
Millennium
ORGANIZATIONTrigger Event
ORGANIZATIONThis Confidential Memorandum
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATION