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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
ts investments from outside investors and primarily invests its capital in the Master Partnership (or its underlying strategies) indirectly through Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi
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
ty company that was formed in 1994. The General Partner also serves as the sole general partner of Millennium USA, Millennium Strategic Capital and Millennium Offshore Intermediate. The General Partner is considered to be under the ultimate control of Israel Englander. The business address and telephone number of the General
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
ty company that was formed in 1994. The General Partner also serves as the sole general partner of Millennium USA, Millennium Strategic Capital and Millennium Offshore Intermediate. The General Partner is considered to be under the ultimate control of Israel Englander. The business address and telephone number of the General
Entities connected to both the "Service and Millennium Offshore Intermediate

New York
LOCATION
United States
LOCATION
New York State
LOCATIONErnst & Young LLP
ORGANIZATION
Millennium
ORGANIZATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATION
U.S. Treasury
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONKeogh
ORGANIZATIONthe State of New York
LOCATIONMillennium USA LP
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONCapital Structure
ORGANIZATION