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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
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
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
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
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
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 Deductibility of Interest 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
LOCATIONDistributions of Property
ORGANIZATIONLehman
ORGANIZATIONthe "Service
ORGANIZATION
U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATION
JPMorgan Chase
ORGANIZATION
the Cayman Islands
LOCATION