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by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distribut
and Millennium USA has been structured, among other reasons, to give U.S. taxpayers an opportunity to invest in the Master Partnership indirectly. Capital Structure Millennium USA and Millennium International and other existing feeder funds have, and feeder funds that may be formed in the future may have, a var
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
ct or indirect subsidiaries that may trade in their own names and are generally consolidated into the financial reports of the Master Partnership. Capital Structure The equity ownership of the Master Partnership is divided into general partner interests and limited partner interests. The interests differ in the
by reducing the amount of short-term capital loss recognized during the tax year in which it receives its liquidating distribution upon withdrawal. Distributions of Property. A partner's receipt of a distribution of property from a partnership is generally not taxable. However, under Section 731 of the Code, a distributi
ct or indirect subsidiaries that may trade in their own names and are generally consolidated into the financial reports of the Master Partnership. Capital Structure The equity ownership of the Master Partnership is divided into general partner interests and limited partner interests. The interests differ in the
Entities connected to both Distributions of Property and Capital Structure

U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATIONCayman
LOCATION
New York
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONMillennium Partners
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONIndividual Limited Partners
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
United States
LOCATION
Ghislaine Maxwell
PERSON
United Kingdom
LOCATION