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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
tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
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
tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
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
tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
Entities connected to both Deductibility of Interest and Management of Millennium USA

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
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium Partners
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