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tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
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
tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
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
tion of the outstanding Offered Interests into another class of Interests of Millennium USA with substantially the same rights and characteristics. Management of Millennium USA The general partner of Millennium USA and the general partner of the Master Partnership is Millennium Management, a Delaware limited liability comp
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
Entities connected to both Management of Millennium USA and Cayman Islands Tax Matters
Ernst & Young LLP
ORGANIZATIONCayman
LOCATION
New York
LOCATION
Millennium
ORGANIZATION
United States
LOCATIONMillennium USA LP
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONthe Cayman Islands Monetary Authority
ORGANIZATIONthe Non-USD Shares
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
U.S. Treasury
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONTrigger Event
ORGANIZATION
England
LOCATIONMillennium Partners
ORGANIZATION
New York State
LOCATIONMillennium USA's
LOCATION
Mohammed bin Salman
PERSONMillennium International, Ltd.
ORGANIZATIONthe "Service
ORGANIZATION