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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
llennium Management. or trusts for the benefit of any member thereof: and any Limited Partner that is an entity directly or indirectly controlled by Millennium Management or Affiliates. DOC ID- 29147063.5 1-36 CONFIDENTIAL UBSTERRAMAR00003967 EFTA00239299 FOR EXISTING INVESTOR USE ONLY each date that an Incentive Allocation
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
lennium Management, or trusts for the benefit of any member thereof: and any Limited Partner that is an entity directly or indirectly controlled by Millennium Management or Affiliates. ML281817-MAXWELL I-37 CONFIDENTIAL UBSTERRAMAR00002367 EFTA00237923 Millennium USA that is not expected to be used will be reversed after Mil
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
lennium Management, or trusts for the benefit of any member thereof: and any Limited Partner that is an entity directly or indirectly controlled by Millennium Management or Affiliates. Me -MAXWELL I-37 CONFIDENTIAL UBSTERRAMAR00001314 EFTA00236960 Millennium USA that is not expected to be used will be reversed after Millenni
Entities connected to both Distributions of Property and Millennium Management or Affiliates

the Cayman Islands
LOCATIONIndividual Limited Partners
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONCayman
LOCATIONKeogh
ORGANIZATIONDeductibility of Interest
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
New York State
LOCATION
United Kingdom
LOCATIONOptions and Special Allocations
ORGANIZATION
the University of Michigan
ORGANIZATIONMunger, Tolles & Olson LLP
ORGANIZATION
Millennium
ORGANIZATION
Luxembourg
LOCATION
Occidental College
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Wilbur Ross
PERSONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION