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ager to review any transactions that require approval under the Advisers Act, including Section 206(3) thereunder, or otherwise. Delaware Act means the Delaware Limited Liability Company Act (6 Del.C. § 18-101 et seq.) as in effect on the date hereof and as amended from time to time, or any successor law. ERISA means the Employee Retire
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
ager to review any transactions that require approval under the Advisers Act, including Section 206(3) thereunder, or otherwise. Delaware Act means the Delaware Limited Liability Company Act (6 Del.C. § 18-101 et seq.) as in effect on the date hereof and as amended from time to time, or any successor law. ERISA means the Employee Retire
itted by any of Millennium's employees or agents or persons acting on their behalf. 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
ager to review any transactions that require approval under the Advisers Act, including Section 206(3) thereunder, or otherwise. Delaware Act means the Delaware Limited Liability Company Act (6 Del.C. § 18-101 et seq.) as in effect on the date hereof and as amended from time to time, or any successor law. ERISA means the Employee Retire
itted by any of Millennium's employees or agents or persons acting on their behalf. 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
Entities connected to both the Delaware Limited Liability Company Act and Cayman Islands Tax Matters

New York
LOCATIONCayman
LOCATION
United States
LOCATION
Mohammed bin Salman
PERSON
New York State
LOCATION
Internal Revenue Service
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
England
LOCATIONthe Certificate of Formation
ORGANIZATIONLehman
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Wilmington
LOCATION
Tokyo
LOCATION
Marc Rich
PERSON
Ghislaine Maxwell
PERSON