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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
d partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Organization," the master-feeder relationsh
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
d partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Organization," the master-feeder relationsh
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
d partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Organization," the master-feeder relationsh
Entities connected to both Schulte Roth & Zabel LLP and Master-Feeder Relationship

United States
LOCATION
New York
LOCATIONKeogh
ORGANIZATION
U.S. Treasury
ORGANIZATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA's
LOCATIONMillennium Partners
ORGANIZATIONTrigger Event
ORGANIZATIONManagement of Millennium USA
ORGANIZATION
Millennium
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONCapital Structure
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONOrganization, Management
ORGANIZATIONthe District of Columbia
LOCATION