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penalties if they fail to comply with special information reporting requirements with respect to their investments in the Partnership. In addition, U.S. Persons that own stock in non-U.S. corporations, including CFCs and PFICs, through the Partnership are subject to special reporting requirements under the C
e Partnership is not required to register or be regulated as a mutual fund under the Mutual Funds Law (2015 Revision) of the Cayman Islands. Neither the Cayman Islands Monetary Authority nor any other governmental authority in the Cayman Islands has commented upon or approved the terms or merits of this document. There is no investm
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(cX3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" unde
s amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are required to be registered with, and regulated by, the Cayman Islands Monetary Authority. The Master Partnership is registered pursuant to the Mutual Funds Law and the consequences of regulation are described below under "Certain Legal
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und
ds 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 registration pursuant to the Mutual Funds Law. The registration process and the consequenc
orated in December 1997 under the laws of the Cayman Islands, which accepts investments from persons who are not "U.S. Persons" and from tax-exempt U.S. Persons (e.g., 501(c)(3) non-profit organizations and individual retirement accounts) that qualify as "accredited investors" and "qualified purchasers" und
ds 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 registration pursuant to the Mutual Funds Law. The registration process and the consequenc
Entities connected to both U.S. Persons and the Cayman Islands Monetary Authority
Cayman
LOCATION
United States
LOCATION
United Kingdom
LOCATIONReliance
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
JPMorgan Chase
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
the Cayman Islands
LOCATION
Millennium
ORGANIZATION
Luxembourg
LOCATION
Tokyo
LOCATIONErnst & Young LLP
ORGANIZATION
Mohammed bin Salman
PERSON
New York
LOCATIONMillennium USA LP
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
New York State
LOCATIONCayman Islands Tax Matters
ORGANIZATION
England
LOCATION