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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
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
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
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
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
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 U.S. Limited and Application of Basis

Occidental College
ORGANIZATIONCayman
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
the Cayman Islands
LOCATIONthe U.S. Investment Advisers Act
ORGANIZATIONReliance
ORGANIZATIONMillennium USA LP
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
U.S. Treasury
ORGANIZATIONOptions and Special Allocations
ORGANIZATION
Mohammed bin Salman
PERSONMunger, Tolles & Olson LLP
ORGANIZATION
United Kingdom
LOCATIONErnst & Young LLP
ORGANIZATIONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
England
LOCATIONMillennium USA's
LOCATION
Wilbur Ross
PERSON