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s Investment Program and Description: Leverage and Loans 64 The Fund's Risk Management Program 65 The Master Partnership's Fees and Expenses 65 Related-Party Transactions and Other Accounts; Conflicts 67 Certain Tax Matters Relating to the Master Partnership 77 Certain Legal and Regulatory Matters Relating to the F
00239344 FOR EXISTING INVESTOR USE ONLY 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 Caym
cation of ongoing expenses related to such utilization in accordance with Millennium's expense allocation policies as in effect from time to time. Related-Party Transactions and Other Accounts; Conflicts Conflicts of interest among the Fund (and investors in the Feeder Funds), Millennium and Millennium's principals may
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
l be allocated among the Fund and such other recipients of the services or the other applicable parties that receive the benefit of such services. Related-Party Transactions; Conflicts Conflicts of interest among the Fund (and investors in the Feeder Funds), Millennium and Millennium's principals may and do exist, which
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
l be allocated among the Fund and such other recipients of the services or the other applicable parties that receive the benefit of such services. Related-Party Transactions; Conflicts Conflicts of interest among the Fund (and investors in the Feeder Funds), Millennium and Millennium's principals may and do exist, which
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 Related-Party Transactions and Cayman Islands Tax Matters
Ernst & Young LLP
ORGANIZATIONCayman
LOCATION
New York
LOCATION
Millennium
ORGANIZATION
New York State
LOCATION
Mohammed bin Salman
PERSON
England
LOCATION
United States
LOCATIONMillennium USA LP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATIONCayman Islands Mutual Funds Law
ORGANIZATION
Marc Rich
PERSONAlphaKeys Millennium Fund
ORGANIZATION
UBS AG
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATIONMillennium Management LLC
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATION