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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
ip") and may also invest through separate legal entities directly in the Master Partnership's underlying strategies. In addition to Millennium USA, Millennium International, Ltd. ("Millennium International") also accepts investments from outside investors and primarily invests its capital in the Master Partnership (or its un
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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
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
Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, L.P. (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P
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
." Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •.,
Entities connected to both Schulte Roth & Zabel LLP and Millennium International, Ltd.

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