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nvestor (the "Investor Application"). -42- CONFIDENTIAL UBSTERRAMAR00003904 EFTA00239236 FOR EXISTING INVESTOR USE ONLY VL TAX ASPECTS Certain Material United States Federal Income Tax Considerations The following is a general summary of certain U.S. federal income tax considerations relating to an investment in
Investment Program and Strategy 26 Use of Proceeds by Millennium USA 26 Millennium USA's Organization, Management, Structure, and Operations 26 Management of Millennium USA 32 The Administrator 33 Fees and Expenses Relating to Millennium USA 34 Allocation of Gains and Losses 36 Outline of the Partnership Agreemen
prospective Investor (the "Investor Application"). ML281817-MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00002305 EFTA00237861 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
ment Program and Strategy 1-26 Use of Proceeds by Millennium USA I-26 Millennium USA's Organization, Management, Structure, and Operations 1-26 Management of Millennium USA I-33 The Administrator I-33 Fees and Expenses Relating to Millennium USA 1-35 Allocation of Gains and Losses 1-36 Outline of the Partnership
by each prospective Investor (the "Investor Application"). MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00001252 EFTA00236898 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
ment Program and Strategy 1-26 Use of Proceeds by Millennium USA I-26 Millennium USA's Organization, Management, Structure, and Operations 1-26 Management of Millennium USA I-33 The Administrator I-33 Fees and Expenses Relating to Millennium USA 1-35 Allocation of Gains and Losses 1-36 Outline of the Partnership
Entities connected to both Material United States and Management of Millennium USA

United States
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONCayman
LOCATIONTrigger Event
ORGANIZATION
Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONThe Master Partnership's Organization
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATIONMillennium Offshore Intermediate
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONKeogh
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONCapital Structure
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATION