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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
ant to the Mutual Funds Law and the consequences of regulation are described below under "Certain Legal and Regulatory Matters Relating to the Fund— Cayman Islands Mutual Funds Law." Regulatory Actions From lime to time, in the ordinary course of operations, certain of the Fund's businesses are subject to regulatory inquiries
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
d under the Exchange Act and may in the future have a broker- dealer entity registered under the Exchange Act or another similarly regulated entity. Cayman Islands Mutual Funds Law Pursuant to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mutual Funds Law) are re
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
under the Exchange Act and may in the future have a broker-dealer entity registered under the Exchange Act or another similarly regulated entity. Cayman Islands Mutual Funds Law Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mut
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
under the Exchange Act and may in the future have a broker-dealer entity registered under the Exchange Act or another similarly regulated entity. Cayman Islands Mutual Funds Law Pursuant to recent amendments to the Mutual Funds Law (as amended) of the Cayman Islands (the "Law"), certain "master funds" (as defined in the Mut
Entities connected to both Cayman Islands Tax Matters and Cayman Islands Mutual Funds Law
the Cayman Islands Monetary Authority
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA LP
ORGANIZATIONthe Non-USD Shares
ORGANIZATION
Mohammed bin Salman
PERSONCayman
LOCATION
England
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATION
New York State
LOCATIONLegal and Regulatory Matters Relating
ORGANIZATION
JPMorgan Chase
ORGANIZATION
Marc Rich
PERSONThe Fund's Risk Management Program
ORGANIZATIONLehman
ORGANIZATIONMillennium Management LLC
ORGANIZATION
Tokyo
LOCATIONthe Exempted Limited Partnership Law
ORGANIZATIONRelated-Party Transactions
ORGANIZATION