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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
ncurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
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
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
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
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
Entities connected to both the "Service and Application of Basis

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