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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
Fund's Investment Program and Strategy 8 The Master Partnership's Organization 9 Certain Risk Factors Relating to an Investment in the Fund 11 The Fund's Management, Structure and Operations 50 The Fund's Investment Program and Description: Eligible Investments 54 The Fund's Investment Program and Description: Investment Strategies an
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
nvestment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investment Program and Description: Eligible Investments 11-42 The Fund's Investment Program and Description: Investment Strateg
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
nvestment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investment Program and Description: Eligible Investments 11-42 The Fund's Investment Program and Description: Investment Strateg
Entities connected to both Schulte Roth & Zabel LLP and The Fund's Management, Structure and Operations

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