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e rules and regulations promulgated thereunder (the "3(c)(1) Fund") and SAB Overseas Fund, Ltd., an exempted company organized under the laws of the Cayman islands for non-U.S. investors and for certain tax-exempt U.S. investors (the "Offshore Fund"), each of which has an investment program substantial
period for the securities involved and may defer the recognition of losses with respect to such securities. 499055.21 EFTA00310665 Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
(ii) a police officer of the rank of constable or higher, or the Financial Reporting Authority, pursuant to the Terrorism Law (2018 Revision) of the Cayman Islands, if the disclosure relates to involvement with terrorism or terrorist financing and property. Such a report will not be treated as a breach
Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)
Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
rtnership: Taxation of Millennium USA and the Master Partnership. Millennium USA is a Delaware limited partnership and the Master Partnership is a Cayman limited partnership. Foreign (non-Japanese) entities are generally classified for Japanese tax purposes as either a separate legal person (houjin)
Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
Entities connected to both Cayman and Deductibility of Interest

United States
LOCATION
Ghislaine Maxwell
PERSON
the Cayman Islands
LOCATION
U.S. Treasury
ORGANIZATION
George W. Bush
PERSON
United Kingdom
LOCATION
New York
LOCATIONKeogh
ORGANIZATION
Luxembourg
LOCATION
JPMorgan Chase
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONErnst & Young LLP
ORGANIZATION
New York State
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONMarkel
ORGANIZATION
Millennium
ORGANIZATION
Mohammed bin Salman
PERSON
Dallas
LOCATION
Wilbur Ross
PERSON