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artnership will be received free of all Cayman Islands taxes. The Master Partnership is registered as an "exempted limited partnership" pursuant to the Exempted Limited Partnership Law (as amended). The Master Partnership has received an undertaking from the Governor in Cabinet of the Cayman Islands dated November 28, 2000 to the
o allocated or the Negative Basis of each such Negative Basis Member shall have been eliminated and (ii) to allocate any losses not so allocated to Negative Basis Members to the other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
artnership will be received free of all Cayman Islands taxes. The Master Partnership is registered as an "exempted limited partnership" pursuant to the Exempted Limited Partnership Law (as amended). The Master Partnership has received an undertaking from the Governor in Cabinet of the Cayman Islands dated November 28, 2000 to the
o allocated or the Negative Basis of each such Negative Basis Member shall have been eliminated and (ii) to allocate any losses not so allocated to Negative Basis Members to the other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
artnership will be received free of all Cayman Islands taxes. The Master Partnership is registered as an "exempted limited partnership" pursuant to the Exempted Limited Partnership Law (as amended). The Master Partnership has received an undertaking from the Governor in Cabinet of the Cayman Islands dated November 28, 2000 to the
o allocated or the Negative Basis of each such Negative Basis Member shall have been eliminated and (ii) to allocate any losses not so allocated to Negative Basis Members to the other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
Entities connected to both the Exempted Limited Partnership Law and Negative Basis Members
Cayman
LOCATION
Samantha Power
PERSONCayman Islands Tax Matters
ORGANIZATION
New York
LOCATION
Millennium
ORGANIZATION
New York State
LOCATIONLegal and Regulatory Matters Relating
ORGANIZATIONCayman Islands Mutual Funds Law
ORGANIZATION
Marc Rich
PERSONMillennium USA LP
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATION
United States
LOCATIONMillennium Management LLC
ORGANIZATIONthe Net Profit or Net Loss
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Mohammed bin Salman
PERSONRelated-Party Transactions
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
England
LOCATIONthe Mutual Funds Law
ORGANIZATION