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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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
Entities connected to both Distributions of Property and Millennium International, Ltd.

Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONMillennium USA's
LOCATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATIONKeogh
ORGANIZATIONErnst & Young LLP
ORGANIZATIONManagement of Millennium USA
ORGANIZATION
United States
LOCATIONTrigger Event
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATION
the Cayman Islands
LOCATIONCapital Structure
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe "Service
ORGANIZATION