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llocated among and credited to or debited against the Capital Accounts of the Members in accordance with their respective Fund Percentages for such Fiscal Period, except to the extent otherwise provided in this Agreement with respect to items of profit or loss that are to be allocated on a non-pro rata basis
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
llocated among and credited to or debited against the Capital Accounts of the Members in accordance with their respective Fund Percentages for such Fiscal Period, except to the extent otherwise provided in this Agreement with respect to items of profit or loss that are to be allocated on a non-pro rata basis
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
llocated among and credited to or debited against the Capital Accounts of the Members in accordance with their respective Fund Percentages for such Fiscal Period, except to the extent otherwise provided in this Agreement with respect to items of profit or loss that are to be allocated on a non-pro rata basis
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 Fiscal Period and Cayman Islands Tax Matters
Cayman
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Mohammed bin Salman
PERSONErnst & Young LLP
ORGANIZATION
Millennium
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
United States
LOCATIONMillennium USA LP
ORGANIZATION
New York State
LOCATION
England
LOCATION
JPMorgan Chase
ORGANIZATION
Tokyo
LOCATION
Wilmington
LOCATIONLehman
ORGANIZATIONRelated-Party Transactions
ORGANIZATION
Samantha Power
PERSONCayman Islands Mutual Funds Law
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATION