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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
sk. The Portfolio Manager may also hedge its investment with a contra-investment in a correlated index or sector rather than a comparable company. Statistical Arbitrage and Quantitative Strategies. U.S. and non-U.S. statistical arbitrage and quantitative strategies generally are quantitatively driven and are employed across the global equity,
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
isk. The Portfolio Manager may also hedge its investment with a contra-investment in a correlated index or sector rather than a comparable company. Statistical Arbitrage and Quantitative Strategies. U.S. and non-U.S. statistical arbitrage and quantitative strategies generally are quantitatively driven and are employed across the global equity,
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
isk. The Portfolio Manager may also hedge its investment with a contra-investment in a correlated index or sector rather than a comparable company. Statistical Arbitrage and Quantitative Strategies. U.S. and non-U.S. statistical arbitrage and quantitative strategies generally are quantitatively driven and are employed across the global equity,
Entities connected to both Cayman Islands Tax Matters and Statistical Arbitrage and Quantitative Strategies
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
ORGANIZATIONCapital Formation International
ORGANIZATIONNovogratz
PERSON
Greenwich
LOCATION