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. Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, L.P. (the "Master Partnership"), a Cayman DOC ID- 29147063.5 CONFIDENTIAL UBSTERRAMAR00003927 EFTA00239259 FOR EXISTING INVESTOR USE ONLY Islands exempted limited partnership initially
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
. Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, L.P. (the "Master Partnership"), a Cayman Islands exempted limited partnership initially organized in 1989 as a Delaware limited partnership, but it may also trade and invest part of its ca
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
gy"). Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, (the "Master Partnership"), a Cayman Islands exempted limited partnership initially organized in 1989 as a Delaware limited partnership, but it may also trade and invest part of its ca
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 Cayman and Material United States

United States
LOCATION
Ghislaine Maxwell
PERSON
UBS AG
ORGANIZATION
U.S. Treasury
ORGANIZATION
Cayman Islands
LOCATION
New York
LOCATIONKeogh
ORGANIZATIONthe District of Columbia
LOCATION
the Internal Revenue Service
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
Paul Volcker
PERSON
Millennium
ORGANIZATION
Philadelphia
LOCATION
Federal Reserve
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONMillennium Partners
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION