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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
o 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 other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
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
o 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 other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
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
o 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 other Members in such manner as shall equitably reflect the amounts allocated to such Members' Capital Accounts pursuant to Sections 5.3(c)
Entities connected to both International Management and Negative Basis Members

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