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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
s amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are required to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership is registered pursuant to the Mutual Funds Law and the consequences of regulation are described below under "Certain Legal
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
ds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for registration pursuant to the Mutual Funds Law. The registration process and the consequenc
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
ds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for registration pursuant to the Mutual Funds Law. The registration process and the consequenc
Entities connected to both Distributions of Property and the Cayman Islands Monetary Authority
Cayman
LOCATION
United States
LOCATIONthe Mutual Funds Law
ORGANIZATIONReliance
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATION
New York
LOCATION
the Cayman Islands
LOCATIONMillennium USA LP
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
New York State
LOCATION
United Kingdom
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONErnst & Young LLP
ORGANIZATION
JPMorgan Chase
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATION
Tokyo
LOCATION
Millennium
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
Occidental College
ORGANIZATION