The Net Capital Appreciation and Net Capital Depreciation
ORGANIZATIONApplication of Basis
ORGANIZATION3
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mited Partner will be subject to a new withdrawal period based on the class of Interest purchased and will be placed in a separate capital account. The Net Capital Appreciation and Net Capital Depreciation attributable to a Limited Partner's capital account for one class of Interest will not be aggregated with, or offset by, the Net Capital Appreciati
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
mited Partner will be subject to a new withdrawal period based on the class of Interest purchased and will be placed in a separate capital account. The Net Capital Appreciation and Net Capital Depreciation attributable to a Limited Partner's capital account for one class of Interest will not be aggregated with, or offset by, the Net Capital Appreciati
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
mited Partner will be subject to a new withdrawal period based on the class of Interest purchased and will be placed in a separate capital account. The Net Capital Appreciation and Net Capital Depreciation attributable to a Limited Partner's capital account for one class of Interest will not be aggregated with, or offset by, the Net Capital Appreciati
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 Net Capital Appreciation and Net Capital Depreciation and Application of Basis

United Kingdom
LOCATION
Mohammed bin Salman
PERSONGovernmental Actions
ORGANIZATIONMillennium USA LP
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
U.S. Treasury
ORGANIZATION
the Cayman Islands
LOCATIONOptions and Special Allocations
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMunger, Tolles & Olson LLP
ORGANIZATION
England
LOCATIONthe Delaware
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONReliance
ORGANIZATION
Wilbur Ross
PERSONKeogh
ORGANIZATION
the University of Michigan
ORGANIZATIONMillennium USA's
LOCATIONLorne
PERSONCayman
LOCATION