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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
ed in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
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
d in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
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
d in an investment in a Feeder Fund. Prospective investors should read Part One and Part Two of this Confidential Memorandum in their entirety and the Partnership Agreement of the Fund, as well as the organizational documents of the Feeder Fund in which they intend to invest and consult with their own advisers before deciding whet
Entities connected to both Application of Basis and the Partnership Agreement of the Fund

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