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n favor of investors in the Fund. Allocation of Investment Strategies and Investments to and Among the Feeder Funds and Other Accounts; Conflicting Investment Opportunities; Cross Transactions In addition to the Feeder Funds and certain related entities through which the Portfolio Managers invest, Millennium has establ
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
icts in a manner that is fair and reasonable. Allocation of Investments to and Among Feeder Funds, Related Accounts and Other Accounts; Conflicting Investment Opportunities; Cross Transactions Although at present Millennium's only clients are the Master Partnership, the Feeder Funds and certain related entities through
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
icts in a manner that is fair and reasonable. Allocation of Investments to and Among Feeder Funds, Related Accounts and Other Accounts; Conflicting Investment Opportunities; Cross Transactions Although at present Millennium's only clients are the Master Partnership, the Feeder Funds and certain related entities through
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 Investment Opportunities and Cayman Islands Tax Matters
the Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATION
JPMorgan Chase
ORGANIZATION
Mohammed bin Salman
PERSONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
England
LOCATION
New York
LOCATION
New York State
LOCATION
United States
LOCATIONLehman
ORGANIZATIONMillennium Management LLC
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATIONInternational Management
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATION