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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
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
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
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
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
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 the Cayman Islands Monetary Authority and Application of Basis
Cayman
LOCATION
United States
LOCATIONthe Mutual Funds Law
ORGANIZATIONthe U.S. Investment Advisers Act
ORGANIZATIONReliance
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
New York State
LOCATION
New York
LOCATION
United Kingdom
LOCATION
JPMorgan Chase
ORGANIZATION
Millennium
ORGANIZATION
Mohammed bin Salman
PERSON
the Cayman Islands
LOCATION
England
LOCATIONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATION
Occidental College
ORGANIZATION