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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
nvestor (the "Investor Application"). -42- CONFIDENTIAL UBSTERRAMAR00003904 EFTA00239236 FOR EXISTING INVESTOR USE ONLY VL TAX ASPECTS Certain Material United States Federal Income Tax Considerations The following is a general summary of certain U.S. federal income tax considerations relating to an investment in
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
prospective Investor (the "Investor Application"). ML281817-MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00002305 EFTA00237861 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
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
by each prospective Investor (the "Investor Application"). MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00001252 EFTA00236898 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
Entities connected to both Schulte Roth & Zabel LLP and Material United States

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