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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
unts of Special Limited Partners4) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
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
benefit of such Limited Partners) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
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
benefit of such Limited Partners) for the year will be reallocated to the capital accounts of Millennium Management as its "Incentive Allocation." The Net Capital Appreciation upon which the calculation of an Incentive Allocation is based is deemed reduced by the unrecovered balance, if any, in a Limited Partner's "Loss R
Entities connected to both the "Service and The Net Capital Appreciation

New York
LOCATION
New York State
LOCATION
United States
LOCATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSONCayman
LOCATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe State of New York
LOCATIONMillennium USA's
LOCATIONCayman Islands Tax Matters
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONTrigger Event
ORGANIZATION
U.S. Treasury
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
the Cayman Islands
LOCATION
England
LOCATIONKeogh
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATION