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Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80 Raffles Place, UOB Plaza 2 #14-20, Singapore 048624, Tel. +65 6505 5000. • Millennium Capital Management Asia Limited, a wholly-owned subsidi
76 CONFIDENTIAL UBSTERRAMAR00004079 EFTA00239411 FOR EXISTING INVESTOR USE ONLY Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80 Raffles Place, UOB Plaza 2 #14-20, Singapore 048624, Tel. +65 6505 5000; • Millennium Capital Management (Asia) Limited, a wholly-owned subs
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80 Raffles Place, UOB Plaza 2 #14-20, Singapore 048624, Tel. I • Millennium Capital Management (Asia) Limited, a wholly-owned subsidiary of Mille
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Entities connected to both the Monetary Authority of Singapore and Cayman Islands Tax Matters

United Kingdom
LOCATION
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Malaysia
LOCATION
Mohammed bin Salman
PERSON
New York
LOCATION
Tokyo
LOCATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATION
Ghislaine Maxwell
PERSON
Millennium
ORGANIZATION
Samantha Power
PERSONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
New York State
LOCATION
England
LOCATIONLehman
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe Securities and Exchange Commission
ORGANIZATION