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perations Classification of Millennium USA and the Master Partnership. Each of Millennium USA and the Master Partnership has received an opinion of Schulte Roth & Zabel LLP, its counsel, that under the provisions of the Code and the Regulations, as in effect on the date of the opinion, as well as under the relevant aut
and Millennium USA has been structured, among other reasons, to give U.S. taxpayers an opportunity to invest in the Master Partnership indirectly. Capital Structure Millennium USA and Millennium International and other existing feeder funds have, and feeder funds that may be formed in the future may have, a var
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
and Millennium USA has been structured, among other reasons, to give U.S. taxpayers an opportunity to invest in the Master Partnership indirectly. Capital Structure Millennium International and Millennium USA have, and Millennium Strategic Capital and any other feeder funds that may be formed in the future may
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
and Millennium USA has been structured, among other reasons, to give U.S. taxpayers an opportunity to invest in the Master Partnership indirectly. Capital Structure Millennium International and Millennium USA have, and Millennium Strategic Capital and any other feeder funds that may be formed in the future may
Entities connected to both Schulte Roth & Zabel LLP and Capital Structure

United States
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium USA's
LOCATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATION
Millennium
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONTrigger Event
ORGANIZATIONIndependent Public Accountants
ORGANIZATION
Paul Volcker
PERSONMaster-Feeder Relationship
ORGANIZATIONthe District of Columbia
LOCATIONMillennium Offshore Intermediate
ORGANIZATION