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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
n in Millennium USA, or their engaging directly, or indirectly through an investment in Millennium USA, in investment strategies of the types which the Master Partnership or Portfolio Managers may utilize from time- to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
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
investment in Millennium USA, in investment ML281817-MAXWELL I-23 CONFIDENTIAL UBSTERRAMAR00002353 EFTA00237909 strategies of the types which the Master Partnership or Portfolio Managers may utilize from time-to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
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
ugh an investment in Millennium USA, in investment .=-MAXWELL I-23 CONFIDENTIAL UBSTERRAMAR00001300 EFTA00236946 strategies of the types which the Master Partnership or Portfolio Managers may utilize from time-to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
Entities connected to both Schulte Roth & Zabel LLP and the Master Partnership or Portfolio Managers

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