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and Millennium USA has been structured, among other reasons, to give U.S. taxpayers an opportunity to invest in the Master Partnership indirectly. Capital Structure Millennium USA and Millennium International and other existing feeder funds have, and feeder funds that may be formed in the future may have, a var
00239344 FOR EXISTING INVESTOR USE ONLY and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Caym
ct or indirect subsidiaries that may trade in their own names and are generally consolidated into the financial reports of the Master Partnership. Capital Structure The equity ownership of the Master Partnership is divided into general partner interests and limited partner interests. The interests differ in the
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
ct or indirect subsidiaries that may trade in their own names and are generally consolidated into the financial reports of the Master Partnership. Capital Structure The equity ownership of the Master Partnership is divided into general partner interests and limited partner interests. The interests differ in the
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Entities connected to both Capital Structure and Cayman Islands Tax Matters

New York
LOCATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATION
Millennium
ORGANIZATION
Ghislaine Maxwell
PERSON
England
LOCATIONthe Non-USD Shares
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
United States
LOCATION
New York State
LOCATIONthe Mutual Funds Law
ORGANIZATION
Mohammed bin Salman
PERSONMaster-Feeder Relationship
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONKeogh
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
U.S. Treasury
ORGANIZATION