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proceeds) made with respect to certain actual and deemed U.S. investments, the Master Partnership has registered with the Internal Revenue Service (the "Service") and generally will be required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including d
onnection with its investment. As used in this Memorandum, the following capitalized terms have the following meanings. "Underlying Fund" refers to Millennium USA LP and any intermediate investment vehicles controlled by the Underlying Fund Manager or its affiliates and into which the Underlying Fund directly or
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
e entities through which the Portfolio Managers and related personnel invest in their strategies, the "Fund"). Currently, the Feeder Funds are: • Millennium USA LP ("Millennium USA"), a Delaware limited partnership formed in November 1997, which accepts investments from taxable U.S. investors that qualify as "
eds) made with respect to certain actual and deemed U.S. investments, the Master Partnership has registered with the U.S. Internal Revenue Service (the "Service") and generally will be required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including de
titute Member who is admitted to the Fund pursuant to Section 4.1 hereof, in such person's capacity as a member of the Fund. Millennium Fund means Millennium USA LP, a Delaware limited partnership. Millennium Investment Manager means Millennium Management LLC, a Delaware limited liability company. Negative Bas
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
e entities through which the Portfolio Managers and related personnel invest in their strategies, the "Fund"). Currently, the Feeder Funds are: • Millennium USA LP ("Millennium USA"), a Delaware limited partnership formed in November 1997, which accepts investments from taxable U.S. investors that qualify as "
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
e entities through which the Portfolio Managers and related personnel invest in their strategies, the "Fund"). Currently, the Feeder Funds are: • Millennium USA LP ("Millennium USA"), a Delaware limited partnership formed in November 1997, which accepts investments from taxable U.S. investors that qualify as "
Entities connected to both the "Service and Millennium USA LP

United States
LOCATION
New York
LOCATION
Millennium
ORGANIZATION
New York State
LOCATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATION
England
LOCATION
Mohammed bin Salman
PERSONthe State of New York
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATIONMillennium Management LLC
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
Ghislaine Maxwell
PERSONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATIONLehman
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATION