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e Net Capital Depreciation or increase the balance of the Loss Recovery Account. In connection with the (i) downsizing of Millennium USA following a Trigger Event, or (ii) dissolution of Millennium USA, reserves for liabilities will be established for the estimated costs of downsizing or liquidating assets an
00239344 FOR EXISTING INVESTOR USE ONLY 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 Caym
be deemed to be made on a first-in first-out basis absent specific instructions to the contrary from the investor. Special Withdrawal Right upon a Trigger Event. Millennium Management will notify the Limited Partners within 10 days of the occurrence of the death, disability, adjudication of incompetency, ba
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
be deemed to be made on a first-in first-out basis absent specific instructions to the contrary from the investor. Special Withdrawal Right upon a Trigger Event. Millennium Management will notify the Limited Partners within 10 days of the occurrence of the death, disability, adjudication of incompetency, ba
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 Trigger Event and Cayman Islands Tax Matters

New York
LOCATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATION
United States
LOCATIONMillennium USA LP
ORGANIZATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATIONManagement of Millennium USA
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATION
Mohammed bin Salman
PERSONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
England
LOCATION
the Internal Revenue Service
ORGANIZATION
U.S. Treasury
ORGANIZATION