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he Members on a basis which is not in accordance with the respective Fund Percentages of all Members as of the commencement of such Fiscal Period. Offering Memorandum means each of the Confidential Offering Memorandums of the Fund, including the Confidential Offering Memorandum of Class A Interests of the Fund, da
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
he Members on a basis which is not in accordance with the respective Fund Percentages of all Members as of the commencement of such Fiscal Period. Offering Memorandum means the Confidential Offering Memorandum of the Fund, dated April 2014, as may be amended or supplemented from time to time. Original Agreement s
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
he Members on a basis which is not in accordance with the respective Fund Percentages of all Members as of the commencement of such Fiscal Period. Offering Memorandum means the Confidential Offering Memorandum of the Fund, dated April 2014, as may be amended or supplemented from time to time. Original Agreement s
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 Offering Memorandum and Cayman Islands Tax Matters

United States
LOCATIONthe Securities and Exchange Commission
ORGANIZATIONCayman
LOCATION
Mohammed bin Salman
PERSON
England
LOCATION
JPMorgan Chase
ORGANIZATION
New York
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
New York State
LOCATIONErnst & Young LLP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONLehman
ORGANIZATIONthe Monetary Authority of Singapore
ORGANIZATION
Tokyo
LOCATIONRelated-Party Transactions
ORGANIZATION
Marc Rich
PERSONLegal and Regulatory Matters Relating
ORGANIZATION