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butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
d partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Organization," the master-feeder relationsh
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
that Millennium determines are appropriate for the Fund. The Master Partnership's Organization Organization Organization of the Master Partnership; Master-Feeder Relationship. The Master Partnership was initially organized in 1989 as a Delaware limited partnership and was redomiciled in the Cayman Islands as of January I
butive share of Millennium USA's taxable income and gain regardless of whether it has received or will receive a distribution from Millennium USA. Allocation of Profits and Losses. Under the Partnership Agreement, Millennium USA's net capital appreciation or net capital depreciation for each accounting period is allocated amon
that Millennium determines are appropriate for the Fund. The Master Partnership's Organization Organization Organization of the Master Partnership; Master-Feeder Relationship. The Master Partnership was initially organized in 1989 as a Delaware limited partnership and was redomiciled in the Cayman Islands as of January I
Entities connected to both Allocation of Profits and Losses and Master-Feeder Relationship
Reliance
ORGANIZATIONthe Offered Interests
ORGANIZATIONAccounting Period
ORGANIZATION
New York
LOCATIONErnst & Young LLP
ORGANIZATIONKeogh
ORGANIZATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATIONCapital Structure
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
U.S. Treasury
ORGANIZATIONCayman
LOCATIONTrigger Event
ORGANIZATION
United States
LOCATION
Millennium
ORGANIZATIONIndependent Public Accountants
ORGANIZATION
the Cayman Islands
LOCATION