Epstein Secrets

and 80% to the General Partner until Carried Interest Distributions generated by Investments that have been disposed of equal 20% of the sum of (i) the Limited Partner's Excess Cumulative Distributions and (ii) the Carried Interest Distributions, in each case with respect to such Investments; and (d) thereafter, 80

penalties if they fail to comply with special information reporting requirements with respect to their investments in the Partnership. In addition, U.S. Persons that own stock in non-U.S. corporations, including CFCs and PFICs, through the Partnership are subject to special reporting requirements under the C

generally be made, subject to audit adjustments, after completion of the audit. If the amount of a withdrawal exceeds 90% of the aggregate value of the Limited Partner's Offered Interests (after taking into account any adjustments made in connection with the audit) immediately prior to the applicable withdrawal date

orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(cX3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" unde

e Allocation made to Millennium Management be returned to the Limited Partner. Appropriate fiscal year-end adjustments, if required, will be made to the Limited Partner's Loss Recovery Accounts. After an Incentive Allocation has been made from a Limited Partner's capital accounts, such capital accounts that are part

orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und

e Allocation made to Millennium Management be returned to the Limited Partner. Appropriate fiscal year-end adjustments, if required, will be made to the Limited Partner's Loss Recovery Accounts. After an Incentive Allocation has been made from a Limited Partner's capital accounts, such capital accounts that are part

orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und