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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
osses may be incurred on both the underlying position and the hedge position simultaneously. The Fund also engages in currency hedging on behalf of Millennium International to hedge the currency exposure of certain classes of Millennium International that are denominated in currencies other than the U.S. dollar. Such c
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
osses may be incurred on both the underlying position and the hedge position simultaneously. The Fund also engages in currency hedging on behalf of Millennium International to hedge the currency exposure of certain classes of Millennium International that are denominated in currencies other than the U.S. dollar. Such c
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
osses may be incurred on both the underlying position and the hedge position simultaneously. The Fund also engages in currency hedging on behalf of Millennium International to hedge the currency exposure of certain classes of Millennium International that are denominated in currencies other than the U.S. dollar. Such c
Entities connected to both Cayman Islands Tax Matters and Millennium International
the Cayman Islands Monetary Authority
ORGANIZATION
New York State
LOCATIONthe 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
United States
LOCATION
Tokyo
LOCATIONLehman
ORGANIZATION
JPMorgan Chase
ORGANIZATIONMillennium Management LLC
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATIONCayman Islands Mutual Funds Law
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATION