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Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
2 mentions1 same-page
Page ?Same page
Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
2 mentions1 same-page
Page ?Same page
Investors should consult their tax advisors regarding the application of the "straddle" rules to their investment in Millennium USA. Limitation on Deductibility of Interest and Short Sale Expenses. For noncorporate taxpayers, Section 163(d) of the Code limits the deduction for "investment interest" (i.e., interest or
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
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Mutual Connections (205)
Entities connected to both Deductibility of Interest and Allocation of Profits and Losses
the Offered Interests
ORGANIZATION3 w/ Deductibility·7 w/ Allocation
Accounting Period
ORGANIZATION3 w/ Deductibility·7 w/ Allocation
Reliance
ORGANIZATION3 w/ Deductibility·7 w/ Allocation
the Cayman Islands
LOCATION4 w/ Deductibility·4 w/ Allocation
New York
LOCATION4 w/ Deductibility·4 w/ Allocation
Keogh
ORGANIZATION4 w/ Deductibility·3 w/ Allocation
U.S. Treasury
ORGANIZATION4 w/ Deductibility·3 w/ Allocation
Distributions of Property
ORGANIZATION4 w/ Deductibility·3 w/ Allocation
Cayman
LOCATION4 w/ Deductibility·3 w/ Allocation
Individual Limited Partners
ORGANIZATION4 w/ Deductibility·3 w/ Allocation
United States
LOCATION3 w/ Deductibility·4 w/ Allocation
Options and Special Allocations
ORGANIZATION3 w/ Deductibility·3 w/ Allocation
Munger, Tolles & Olson LLP
ORGANIZATION3 w/ Deductibility·3 w/ Allocation
New York State
LOCATION3 w/ Deductibility·3 w/ Allocation
the Partnership Agreement of the Fund
ORGANIZATION3 w/ Deductibility·3 w/ Allocation
a Master's in Information Systems
ORGANIZATION3 w/ Deductibility·3 w/ Allocation
SL
Simon M. Lorne
PERSON3 w/ Deductibility·3 w/ Allocation
the U.S. Investment Advisers Act
ORGANIZATION3 w/ Deductibility·3 w/ Allocation
England
LOCATION3 w/ Deductibility·3 w/ Allocation
the "Service
ORGANIZATION3 w/ Deductibility·3 w/ Allocation