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ts from the Feeder Funds or increased resistance of investors to make new investments. Regulation Under the Laws of the Cayman Islands Pursuant to the Mutual Funds Law (as amended) of the Cayman Islands, certain "master funds" (as defined in the Mutual Funds Law) are required to be registered with, and regulated b
00239344 FOR EXISTING INVESTOR USE ONLY and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Caym
e have a broker- dealer entity registered under the Exchange Act or another similarly regulated entity. Cayman Islands Mutual Funds Law Pursuant to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mutual Funds Law) are required to be registered with, and
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
the Cayman Islands Pursuant to recent amendments to the Mutual Funds 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 regist
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
nds Law Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority (the "Monetary Authority"). The Master Partnership has submitt
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
the Cayman Islands Pursuant to recent amendments to the Mutual Funds 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 regist
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
nds Law Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mutual Funds Law) are to be registered with, and regulated by, the Cayman Islands Monetary Authority (the "Monetary Authority"). The Master Partnership has submitt
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 the Mutual Funds Law and Cayman Islands Tax Matters
Cayman
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
England
LOCATIONMillennium USA LP
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Millennium
ORGANIZATION
New York
LOCATION
New York State
LOCATION
Mohammed bin Salman
PERSON
United States
LOCATION
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATIONLehman
ORGANIZATIONthe "Service
ORGANIZATION
Marc Rich
PERSONthe State of New York
LOCATIONDavid Nolan
PERSONMillennium Management LLC
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATION