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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
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
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
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
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
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
Entities connected to both the "Service and U.S. Limited

New York
LOCATION
United States
LOCATION
New York State
LOCATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATIONthe State of New York
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
the Cayman Islands
LOCATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSON
Millennium
ORGANIZATIONMillennium USA's
LOCATIONCayman Islands Tax Matters
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONReliance
ORGANIZATIONTrigger Event
ORGANIZATION
U.S. Treasury
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATION