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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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere in this Confidential Memorandum. This summary should be read in conjunction with, and is qualified i
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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in i
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
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in its e
Entities connected to both Deductibility of Interest and Millennium Partners

New York
LOCATION
U.S. Treasury
ORGANIZATIONCayman
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium USA's
LOCATIONErnst & Young LLP
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONKeogh
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
Millennium
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONTrigger Event
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONCapital Structure
ORGANIZATION
the Cayman Islands
LOCATION
United States
LOCATIONIndependent Public Accountants
ORGANIZATIONIndividual Limited Partners
ORGANIZATIONDistributions of Property
ORGANIZATION