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ght to receive any allocations and distributions attributable to an Interest. Unaffiliated Fund Percentages means a percentage established for each Unaffiliated Member on the Fund's books as of the first day of each Fiscal Period. The Unaffiliated Fund Percentage of an Unaffiliated Member shall be determine
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
Section 2.8 hereof. ML281817-MAXWELL B-2 CONFIDENTIAL UBSTERRAMAR00002483 EFTA00238039 Closing Date means the first date on or as of which an Unaffiliated Member is admitted to the Fund. Code means the United States Internal Revenue Code of 1986, as amended and as hereafter amended from time to time,
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
orth in Section 2.8 hereof. -MAXWELL B-2 CONFIDENTIAL UBSTERFtAMAR00001430 EFTA00237076 Closing Date means the first date on or as of which an Unaffiliated Member is admitted to the Fund. Code means the United States Internal Revenue Code of 1986, as amended and as hereafter amended from time to time,
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 Unaffiliated and Cayman Islands Tax Matters

New York
LOCATIONCayman
LOCATIONthe Non-USD Shares
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
United States
LOCATIONMillennium USA LP
ORGANIZATION
New York State
LOCATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATION
Tokyo
LOCATIONthe Confidential Information
ORGANIZATIONLehman
ORGANIZATIONRestated Limited Liability Company Agreement
ORGANIZATION
JPMorgan Chase
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATION
Marc Rich
PERSONRelated-Party Transactions
ORGANIZATION