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eports with the SEC. These reports are available through the SEC's EDGAR database, which can be accessed through the SEC's web site (www.sec.gov). Broker-Dealer and Other Similar Registrations. Millennium has in the past had a broker-dealer entity registered under the Exchange Act and may in the future have
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
eports with the SEC. These reports are available through the SEC's EDGAR database, which can be accessed through the SEC's web site (www.sec.gov). Broker-Dealer and Other Similar Registrations. Millennium has in the past had a broker-dealer entity registered under the Exchange Act and may in the future have
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
eports with the SEC. These reports are available through the SEC's EDGAR database, which can be accessed through the SEC's web site (www.sec.gov). Broker-Dealer and Other Similar Registrations. Millennium has in the past had a broker-dealer entity registered under the Exchange Act and may in the future have
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 Broker-Dealer and Cayman Islands Tax Matters

New York
LOCATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSONCayman
LOCATION
England
LOCATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATIONLehman
ORGANIZATION
JPMorgan Chase
ORGANIZATION
United States
LOCATION
Tokyo
LOCATIONCayman Islands Mutual Funds Law
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATIONRelated-Party Transactions
ORGANIZATIONMillennium Management LLC
ORGANIZATION
Marc Rich
PERSON