Epstein Secrets

strategies and the entities through which the Portfolio Managers (as defined below) and related personnel invest in their strategies, the "Fund"). Millennium Management LLC, a Delaware limited liability company registered in the Cayman Islands, is the sole general partner of the Master Partnership (the "General Partner

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

n's capacity as a member of the Fund. Millennium Fund means Millennium USA LP, a Delaware limited partnership. Millennium Investment Manager means Millennium Management LLC, a Delaware limited liability company. Negative Basis means, with respect to any Member and as of any time of calculation, the amount by which the

76 CONFIDENTIAL UBSTERRAMAR00004079 EFTA00239411 FOR EXISTING INVESTOR USE ONLY Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U

n's capacity as a member of the Fund. Millennium Fund means Millennium USA LP, a Delaware limited partnership. Millennium Investment Manager means Millennium Management LLC, a Delaware limited liability company. Negative Basis means, with respect to any Member and as of any time of calculation, the amount by which the

itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U

n's capacity as a member of the Fund. Millennium Fund means Millennium USA LP, a Delaware limited partnership. Millennium Investment Manager means Millennium Management LLC, a Delaware limited liability company. Negative Basis means, with respect to any Member and as of any time of calculation, the amount by which the

itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U