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rtner should not be subject to New York State personal income tax with respect to his share of income or gain realized directly by Millennium USA. Individual Limited Partners who are residents of New York State and New York City should be aware that the New York State and New York City personal income tax laws limit the
ncurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
rtner should not be subject to New York State personal income tax with respect to his share of income or gain realized directly by Millennium USA. Individual Limited Partners who are residents of New York State and New York City should be aware that the New York State and New York City personal income tax laws limit the
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
rtner should not be subject to New York State personal income tax with respect to his share of income or gain realized directly by Millennium USA. Individual Limited Partners who are residents of New York State and New York City should be aware that the New York State and New York City personal income tax laws limit the
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
Entities connected to both Individual Limited Partners and Application of Basis

the Cayman Islands
LOCATIONDeductibility of Interest
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONCayman
LOCATIONKeogh
ORGANIZATIONDistributions of Property
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
New York State
LOCATION
United Kingdom
LOCATIONOptions and Special Allocations
ORGANIZATION
the University of Michigan
ORGANIZATIONMunger, Tolles & Olson LLP
ORGANIZATION
Millennium
ORGANIZATION
Luxembourg
LOCATION
Occidental College
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Wilbur Ross
PERSONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION