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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
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
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
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
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
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 Allocation of Profits and Losses and The Net Capital Appreciation
Accounting Period
ORGANIZATIONReliance
ORGANIZATIONthe Offered Interests
ORGANIZATION
New York
LOCATION
the Cayman Islands
LOCATION
the University of Michigan
ORGANIZATIONGovernmental Actions
ORGANIZATIONMillennium USA LP
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
New York State
LOCATIONOptions and Special Allocations
ORGANIZATION
Millennium
ORGANIZATIONMunger, Tolles & Olson LLP
ORGANIZATION
Luxembourg
LOCATION
Occidental College
ORGANIZATION
Wilbur Ross
PERSONErnst & Young LLP
ORGANIZATION
Mohammed bin Salman
PERSONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION