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s and Expenses 65 Related-Party Transactions and Other Accounts; Conflicts 67 Certain Tax Matters Relating to the Master Partnership 77 Certain Legal and Regulatory Matters Relating to the Fund 79 The Master Partnership's Fiscal Year 82 The Master Partnership's Independent Public Accountants 82 Appendix I: Relying Advisers
00239344 FOR EXISTING INVESTOR USE ONLY and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Caym
vant to an investment in a particular Feeder Fund have been included in Part One of the applicable version of this Confidential Memorandum. Certain Legal and Regulatory Matters Relating to the Fund U.S. Investment Company Act As entities that are engaged primarily in the business of "investing, reinvesting, or trading in securitie
76 CONFIDENTIAL UBSTERRAMAR00004079 EFTA00239411 FOR EXISTING INVESTOR USE ONLY Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
vant to an investment in a particular Feeder Fund have been included in Part One of the applicable version of this Confidential Memorandum. Certain Legal and Regulatory Matters Relating to the Fund United States Investment Comparry Act As entities that are engaged primarily in the business of "investing, reinvesting, or trading in
itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
vant to an investment in a particular Feeder Fund have been included in Part One of the applicable version of this Confidential Memorandum. Certain Legal and Regulatory Matters Relating to the Fund United States Investment Comparry Act As entities that are engaged primarily in the business of "investing, reinvesting, or trading in
itted by any of Millennium's employees or agents or persons acting on their behalf. Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
Entities connected to both Legal and Regulatory Matters Relating and Cayman Islands Tax Matters
the Cayman Islands Monetary Authority
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSONCayman
LOCATION
England
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATION
New York State
LOCATION
Marc Rich
PERSON
JPMorgan Chase
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATION
Tokyo
LOCATIONLehman
ORGANIZATIONMillennium Management LLC
ORGANIZATIONRelated-Party Transactions
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATIONCayman Islands Mutual Funds Law
ORGANIZATION