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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
N RELATING TO MILLENNIUM PARTNERS, L.P. Sununary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy II-8 The Master Partnership's Organization 11-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management. Structure and Operations II-46 The Fund's Investm
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
ON RELATING TO MILLENNIUM PARTNERS, L.P. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investme
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
TION RELATING TO MILLENNIUM PARTNERS, M. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investme
Entities connected to both Material United States and The Master Partnership's Organization

United States
LOCATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONCayman
LOCATIONTrigger Event
ORGANIZATION
Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATION
New York
LOCATIONManagement of Millennium USA
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