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nt entity) and apply the proceeds toward the discharge of the loans. These loans have been structured in a way that seeks to ensure that Millennium International Management does not receive any additional pecuniary benefit from owning these entities. The ownership structure of these entities may change from time to time
follows: (i) to allocate such losses among such Negative Basis Members until either the full amount of such losses shall have been so 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 oth
ia Entity) and apply the proceeds toward the discharge of the loans. These loans have been structured in a way that seeks to ensure that Millennium International Management does not receive any additional pecuniary benefit from owning ML281817-MAXWELL 11-58 CONFIDENTIAL UBSTERRAMAR00002474 EFTA00238030 the Asia En
follows: (i) to allocate such losses among such Negative Basis Members until either the full amount of such losses shall have been so 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 oth
ia Entity) and apply the proceeds toward the discharge of the loans. These loans have been structured in a way that seeks to ensure that Millennium International Management does not receive any additional pecuniary benefit from owning 11= -MAXWELL 11-58 CONFIDENTIAL UBSTERRAMAR00001421 EFTA00237067 the Asia Entiti
follows: (i) to allocate such losses among such Negative Basis Members until either the full amount of such losses shall have been so 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 oth
Entities connected to both International Management and the Negative Basis

United States
LOCATION
Samantha Power
PERSONthe Cayman Islands Monetary Authority
ORGANIZATION
Marc Rich
PERSON
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATIONInvestment Opportunities
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATIONCayman
LOCATION
UBS AG
ORGANIZATIONthe Positive Basis
ORGANIZATION
Department of Justice
ORGANIZATION
New York State
LOCATION
Internal Revenue Service
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe Confidential Information
ORGANIZATIONRestated Limited Liability Company Agreement
ORGANIZATIONthe Delaware Limited Liability Company Act
ORGANIZATIONAnti-Money Laundering Regulations
ORGANIZATION
Fannie Mae
ORGANIZATION