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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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
Entities connected to both Distributions of Property and the Non-USD Shares
Cayman
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATION
England
LOCATION
New York State
LOCATION
Mohammed bin Salman
PERSON
Millennium
ORGANIZATIONCayman Islands Tax Matters
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