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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
00239344 FOR EXISTING INVESTOR USE ONLY and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Caym
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
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
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
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Entities connected to both Distributions of Property and Cayman Islands Tax Matters
Cayman
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATION
England
LOCATION
New York State
LOCATION
Mohammed bin Salman
PERSON
Millennium
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATIONMillennium USA LP
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATION
United States
LOCATIONDeductibility of Interest
ORGANIZATIONLehman
ORGANIZATIONthe "Service
ORGANIZATION
U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATION
JPMorgan Chase
ORGANIZATION
the Cayman Islands
LOCATION