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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
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
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
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
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
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. Persons and Application of Basis

United Kingdom
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
the University of Michigan
ORGANIZATIONReliance
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATIONKeogh
ORGANIZATIONCayman
LOCATION
Luxembourg
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONthe Limited Partner's
ORGANIZATION
the Cayman Islands
LOCATIONthe Partnership Agreement of the Fund
ORGANIZATIONSelf-Regulatory Organizations
ORGANIZATION
Wilbur Ross
PERSON
Millennium
ORGANIZATION
Occidental College
ORGANIZATIONMisconduct of Employees
ORGANIZATION
Mohammed bin Salman
PERSONthe Non-USD Shares
ORGANIZATION
England
LOCATION