3
Shared Docs
3
Same-Page
3 / 3
Mentions
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere in this Confidential Memorandum. This summary should be read in conjunction with, and is qualified i
ncurred by a partnership in which Millennium USA invests will be subject to the same limitations when allocated to a noncorporate Limited Partner. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, L.P. (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in i
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
ully in the Third Amended and Restated Limited Partnership Agreement, as amended or supplemented from time to time (the "Partnership Agreement") of Millennium Partners, (the "Master Partnership") and elsewhere this Confidential Memorandum. This summary should be read in conjunction with, and is qualified in its e
s of Millennium USA, including investments in partnerships engaged in certain trades or businesses may constitute passive activity income or loss. Application of Basis and "At Risk" Limitations on Deductions. The amount of any loss of Millennium USA that a Limited Partner is entitled to include in its income tax re
Entities connected to both Millennium Partners and Application of Basis
Trigger Event
ORGANIZATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONErnst & Young LLP
ORGANIZATION
New York
LOCATIONManagement of Millennium USA
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATION
Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONCapital Structure
ORGANIZATIONKeogh
ORGANIZATIONIndependent Public Accountants
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATION
United States
LOCATION
the Cayman Islands
LOCATIONMillennium USA LP
ORGANIZATION