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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
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
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
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
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
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 International Management and Cayman Islands Tax Matters

United States
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
JPMorgan Chase
ORGANIZATIONMillennium USA LP
ORGANIZATION
Tokyo
LOCATION
New York
LOCATION
Mohammed bin Salman
PERSON
England
LOCATION
New York State
LOCATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Marc Rich
PERSONLehman
ORGANIZATION
Ghislaine Maxwell
PERSON
Samantha Power
PERSON
UBS AG
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATION