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NFORMATION RELATING TO MILLENNIUM PARTNERS, LP Summary of Part Two of the Confidential Memorandum 1 The Fund's Investment Program and Strategy 8 The Master Partnership's Organization 9 Certain Risk Factors Relating to an Investment in the Fund 11 The Fund's Management, Structure and Operations 50 The Fund's Investment Progra
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
ION RELATING TO MILLENNIUM PARTNERS, L.P Summary 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 The Fund's Management, Structure and Operations 11-37 The Fund's Investment Prog
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
RMATION RELATING TO MILLENNIUM PARTNERS, Summary 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 The Fund's Management, Structure and Operations 11-37 The Fund's Investment Prog
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 Master Partnership's Organization and Application of Basis
Trigger Event
ORGANIZATIONCayman
LOCATIONManagement of Millennium USA
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONErnst & Young LLP
ORGANIZATION
New York
LOCATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATION
Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONCapital Structure
ORGANIZATIONKeogh
ORGANIZATIONIndependent Public Accountants
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATION
United States
LOCATION
the Cayman Islands
LOCATIONMillennium USA LP
ORGANIZATION