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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
y of the Fund were to leave the Fund, the Fund would have no ability to continue to trade the particular strategy using the intellectual property. Formation of Additional Funds Millennium has organized and retains the right to organize additional investment vehicles and to advise additional clients. As set forth below in the
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
folio Manager were to leave the Fund, the Fund would have no ability to continue to trade the particular strategy using the intellectual property. Formation of Additional Funds Although the Master Partnership and the Feeder Funds are the only investment funds currently managed by Millennium and its affiliated management co
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
folio Manager were to leave the Fund, the Fund would have no ability to continue to trade the particular strategy using the intellectual property. Formation of Additional Funds Although the Master Partnership and the Feeder Funds are the only investment funds currently managed by Millennium and its affiliated management co
Entities connected to both Application of Basis and Formation of Additional Funds

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