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r, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raising capital to finance large projects. Prior to working with Applied, Mr. Novogratz hel
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
r, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raising capital to finance large projects. Prior to working with Applied, Mr. Novogratz hel
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
r, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raising capital to finance large projects. Prior to working with Applied, Mr. Novogratz hel
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 Applied Development and Cayman Islands Tax Matters

Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
England
LOCATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATIONLehman
ORGANIZATION
Mohammed bin Salman
PERSON
New York
LOCATION
United States
LOCATIONErnst & Young LLP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATION
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONthe "Service
ORGANIZATION
Goldman Sachs Asset Management
ORGANIZATION
Fortress Investment Group
ORGANIZATIONDavid Nolan
PERSON