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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
OF ACQUIRING, HOLDING AND DISPOSING OF INTERESTS, AS WELL AS THE EFFECTS OF TAX LAWS OF THE JURISDICTIONS OF WHICH THEY ARE CITIZENS, RESIDENTS OR DOMICILIARIES OR IN WHICH THEY CONDUCT BUSINESS. There is, at present, no direct taxation in the Cayman Islands and interest, dividends and gains payable to the
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
OF ACQUIRING, HOLDING AND DISPOSING OF INTERESTS, AS WELL AS THE EFFECTS OF TAX LAWS OF THE JURISDICTIONS OF WHICH THEY ARE CITIZENS, RESIDENTS OR DOMICILIARIES OR IN WHICH THEY CONDUCT BUSINESS. There is, at present, no direct taxation in the Cayman Islands and interest, dividends and gains payable to the
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
OF ACQUIRING, HOLDING AND DISPOSING OF INTERESTS, AS WELL AS THE EFFECTS OF TAX LAWS OF THE JURISDICTIONS OF WHICH THEY ARE CITIZENS, RESIDENTS OR DOMICILIARIES OR IN WHICH THEY CONDUCT BUSINESS. There is, at present, no direct taxation in the Cayman Islands and interest, dividends and gains payable to the
Entities connected to both International Management and DOMICILIARIES

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