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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
d partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Organization," the master-feeder relationsh
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
that Millennium determines are appropriate for the Fund. The Master Partnership's Organization Organization Organization of the Master Partnership; Master-Feeder Relationship. The Master Partnership was initially organized in 1989 as a Delaware limited partnership and was redomiciled in the Cayman Islands as of January I
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
that Millennium determines are appropriate for the Fund. The Master Partnership's Organization Organization Organization of the Master Partnership; Master-Feeder Relationship. The Master Partnership was initially organized in 1989 as a Delaware limited partnership and was redomiciled in the Cayman Islands as of January I
Entities connected to both Distributions of Property and Master-Feeder Relationship

New York
LOCATIONKeogh
ORGANIZATION
U.S. Treasury
ORGANIZATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONMillennium USA's
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONCapital Structure
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONMillennium Partners
ORGANIZATIONTrigger Event
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONIndividual Limited Partners
ORGANIZATIONDeductibility of Interest
ORGANIZATION
United States
LOCATION
the Cayman Islands
LOCATION