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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
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
limited partnership in the Cayman Islands 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 Cayma
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
limited partnership in the Cayman Islands 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 Cayma
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 Cayman Islands Tax Matters and Formation of Additional Funds

New York State
LOCATION
Millennium
ORGANIZATIONthe Mutual Funds Law
ORGANIZATION
England
LOCATIONMillennium USA LP
ORGANIZATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATIONthe Non-USD Shares
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