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llennium International Management. • Catapult Capital Management LLC, a wholly-owned subsidiary of Millennium International Management. • Decade Capital Management LLC, a wholly-owned subsidiary of Millennium International Management. • Green Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium
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
holly-owned subsidiary of Millennium International Management; ML281817-MAXWELL 11-37 CONFIDENTIAL UBSTERRAMAR00002453 EFTA00238009 • Decade Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; • Green Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium
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
LLC, a wholly-owned subsidiary of Millennium International Management; MAXWELL 11-37 CONFIDENTIAL UBSTERRAMAR00001400 EFTA00237046 • Decade Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; • Green Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium
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 Capital Management LLC and Cayman Islands Tax Matters
Cayman
LOCATION
England
LOCATIONthe Non-USD Shares
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
Millennium
ORGANIZATION
United States
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
New York
LOCATION
New York State
LOCATION
Mohammed bin Salman
PERSONMillennium USA LP
ORGANIZATION
JPMorgan Chase
ORGANIZATIONLehman
ORGANIZATION
Tokyo
LOCATIONthe "Service
ORGANIZATION
Greenwich
LOCATIONMillennium International Management LP
ORGANIZATIONthe CLEO Committee
ORGANIZATIONGreen Arrow Capital Management LLC
ORGANIZATION