4
Shared Docs
4
Same-Page
4 / 4
Mentions
"Treasury Regulations") to be treated as a U.S. person. For purposes of this section, a Ron-U.S. Partner" means a Limited Partner that is neither a U.S. Limited Partner nor a partnership (or any other entity treated as a partnership) for U.S. federal income tax purposes. A 'U.S. Tax-Exempt Partner" is a U.S.
ds except in furtherance of the business of the Fund carried on outside the Cayman Islands. The Fund is a regulated mutual fund for the purposes of the Mutual Funds Law and is registered with the Cayman Islands Monetary Authority (-MA") pursuant to section 4(3) of that law. This offering memorandum has been filed wi
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
ts from the Feeder Funds or increased resistance of investors to make new investments. Regulation Under the Laws of the Cayman Islands Pursuant to the Mutual Funds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are required to be registered with, and regulated b
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
the Cayman Islands Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for regist
the Service so as to relieve the Limited Partners of these reporting obligations. Regulations also generally impose a reporting requirement on any U.S. Limited Partner which, at any time during the taxable year of the Master Partnership, owns (indirectly or by attribution) more than 50% of the capital or p
the Cayman Islands Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership has submitted an application for regist
Entities connected to both U.S. Limited and the Mutual Funds Law
the Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATIONMillennium USA LP
ORGANIZATION
England
LOCATION
Mohammed bin Salman
PERSON
United States
LOCATION
Millennium
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONErnst & Young LLP
ORGANIZATION
New York State
LOCATION
New York
LOCATIONReliance
ORGANIZATION
Occidental College
ORGANIZATION
the Cayman Islands
LOCATIONthe U.S. Investment Advisers Act
ORGANIZATION
Tokyo
LOCATIONLehman
ORGANIZATIONthe "Service
ORGANIZATION
JPMorgan Chase
ORGANIZATION