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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
vogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raisi
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
vogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raisi
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
vogratz worked at Fortress Investment Group for almost six years before joining the General Partner, most recently as Managing Director and Head of Capital Formation International in London. Prior to joining Fortress, Mr. Novogratz consulted for Applied Development, a real estate development company, where he focused on raisi
Entities connected to both Cayman Islands Tax Matters and Capital Formation International
the Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
New York
LOCATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATION
United States
LOCATIONLehman
ORGANIZATIONthe "Service
ORGANIZATIONthe Commodity Futures Trading Commission
ORGANIZATIONOngoing Evaluation
ORGANIZATIONNovogratz
PERSON
Greenwich
LOCATION