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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
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(cX3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" unde
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
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und
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
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und
Entities connected to both the "Service and U.S. Persons

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