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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
" and "Certain Tax Matters Relating to the Master Partnership" in Part One of the Underlying Fund Memorandum and "TAX ASPECTS" in this Memorandum. Bank Holding Company Act Considerations. The Administrator is, for purposes of the BHC Act, a subsidiary of UBS, which is subject to supervision and regulation by the Federal Reserve. It i
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
A" and "Certain Tax Matters Relating to the Master Partnership" in Part One of the Underlying Fund Memorandum and "TAX ASPECTS" in this Memorandum. Bank Holding Company Act Considerations. The Administrator is, for purposes of the BHC Act, a subsidiary of UBS AG, which is subject to supervision and regulation by the Federal Reserve.
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
A" and "Certain Tax Matters Relating to the Master Partnership" in Part One of the Underlying Fund Memorandum and "TAX ASPECTS" in this Memorandum. Bank Holding Company Act Considerations. The Administrator is, for purposes of the BHC Act, a subsidiary of UBS AG, which is subject to supervision and regulation by the Federal Reserve.
Entities connected to both Schulte Roth & Zabel LLP and Bank Holding Company Act Considerations

United States
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATIONCayman
LOCATION
the Internal Revenue Service
ORGANIZATION
Paul Volcker
PERSONErnst & Young LLP
ORGANIZATIONKeogh
ORGANIZATIONTrigger Event
ORGANIZATION
UBS AG
ORGANIZATION
Millennium
ORGANIZATIONClasses of Interests
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONThis Confidential Memorandum
ORGANIZATIONthe Investor Application
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONMillennium USA's
LOCATIONMillennium Partners
ORGANIZATIONNo Assurance of Investment Return
ORGANIZATION