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ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou
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
ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou
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
ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou
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
Entities connected to both the "Service and Allocation of Profits and Losses

New York
LOCATION
United States
LOCATION
New York State
LOCATIONthe Offered Interests
ORGANIZATIONAccounting Period
ORGANIZATIONReliance
ORGANIZATIONthe State of New York
LOCATIONMillennium USA LP
ORGANIZATION
Millennium
ORGANIZATIONFederal, State
ORGANIZATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATION
Mohammed bin Salman
PERSON
the Cayman Islands
LOCATIONManagement of Millennium USA
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION