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follows: (i) to allocate such income among such Positive Basis Members until either the full amount of such income shall have been so allocated or the Positive Basis of each such Positive Basis Member shall have been eliminated, and (ii) to allocate any income not so allocated to Positive Basis Members to the ot
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
follows: (i) to allocate such income among such Positive Basis Members until either the full amount of such income shall have been so allocated or the Positive Basis of each such Positive Basis Member shall have been eliminated, and (ii) to allocate any income not so allocated to Positive Basis Members to the ot
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
follows: (i) to allocate such income among such Positive Basis Members until either the full amount of such income shall have been so allocated or the Positive Basis of each such Positive Basis Member shall have been eliminated, and (ii) to allocate any income not so allocated to Positive Basis Members to the ot
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 Positive Basis and Cayman Islands Tax Matters
the Mutual Funds Law
ORGANIZATIONMillennium USA LP
ORGANIZATION
New York State
LOCATION
New York
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATION
Millennium
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Samantha Power
PERSONLehman
ORGANIZATION
Tokyo
LOCATIONMillennium Management LLC
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATIONthe Negative Basis
ORGANIZATIONRelated-Party Transactions
ORGANIZATION