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cording of 1-12 CONFIDENTIAL UBSTERRAMAR00003943 EFTA00239275 FOR EXISTING INVESTOR USE ONLY Taxation: ERISA and Other Tax Exempt Entities: Anti-Money Laundering Considerations: DOC ID- 29147063.5 transactions and the reconciliation of cash, positions and transactions between Millennium USA's and the Maste
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
lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its
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
lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its
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 Anti-Money Laundering and Material United States

United States
LOCATIONthe District of Columbia
LOCATION
U.S. Treasury
ORGANIZATIONCayman
LOCATION
the Internal Revenue Service
ORGANIZATION
New York
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Millennium
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONthe Master Partnership or Portfolio Managers
ORGANIZATIONNon-U.S. Investments
ORGANIZATIONDifferent Returns Among Investors
ORGANIZATION
FDIC
ORGANIZATION
Paul Volcker
PERSONErnst & Young LLP
ORGANIZATIONthe "Intermediate Partnership
ORGANIZATIONClasses of Interests
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONIsrael A. Englander
PERSONMillennium Offshore Intermediate
ORGANIZATION