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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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
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
rne by the holders of the relevant sub-classes of Non-USD Shares. There can be no assurance that the currency hedging activities in connection with the Non-USD Shares will be effective. In addition, there can be no assurance that the currency hedging activities will fully protect investors from a decline in the v
Entities connected to both Application of Basis and the Non-USD Shares

New York State
LOCATION
Millennium
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
England
LOCATIONMillennium USA LP
ORGANIZATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATIONCayman Islands Tax Matters
ORGANIZATION
Mohammed bin Salman
PERSON
New York
LOCATIONthe Cayman Islands Monetary Authority
ORGANIZATION
United States
LOCATIONLehman
ORGANIZATIONthe "Service
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Tokyo
LOCATION
Ghislaine Maxwell
PERSON
Wilbur Ross
PERSON
United Kingdom
LOCATION
U.S. Treasury
ORGANIZATION