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gainst amounts to be paid under Section 6.2(a) above, and (ii) any profit or loss attributable to property distributed in-kind shall be included in the Net Profit or Net Loss for the Fiscal Period ending on the date of such distribution. ARTICLE VIkAccounting, Valuations and Books and Records 7.1 Accounting and Reports
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
gainst amounts to be paid under Section 6.2(a) above, and (ii) any profit or loss attributable to property distributed in-kind shall be included in the Net Profit or Net Loss for the Fiscal Period ending on the date of such distribution. ML281817-MAXWELL B-23 CONFIDENTIAL UBSTERRAMAR00002504 EFTA00238060 ARTICLE VI
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
gainst amounts to be paid under Section 6.2(a) above, and (ii) any profit or loss attributable to property distributed in-kind shall be included in the Net Profit or Net Loss for the Fiscal Period ending on the date of such distribution. MEI-MAXWELL B-23 CONFIDENTIAL UBSTERRAMAR00001451 EFTA00237097 ARTICLE VIkAcco
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
Entities connected to both the Net Profit or Net Loss and Cayman Islands Tax Matters
Cayman
LOCATION
United States
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
New York
LOCATIONthe Non-USD Shares
ORGANIZATIONMillennium USA LP
ORGANIZATION
New York State
LOCATIONErnst & Young LLP
ORGANIZATION
Millennium
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
Tokyo
LOCATIONLehman
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATION
Samantha Power
PERSON
JPMorgan Chase
ORGANIZATION
Marc Rich
PERSONCayman Islands Mutual Funds Law
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATION