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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
as well as competition for investment and management talent. Millennium will attempt to mitigate such conflicts, under the ultimate supervision of the CLEO Committee or any successor body thereto, by making allocations and other judgments on a basis that it believes to be fair and reasonable under the circumstan
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
m the University of Cape Town, South Africa. Mr. Meskin is a member of the Executive Committee, Investment Risk Committee, Valuation Committee and the CLEO Committee of the General Partner. • John Novogratz, 39 Coined in 2009), is a Senior Managing Director and the Global Head of Marketing and Investor Relations
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
m the University of Cape Town, South Africa. Mr. Meskin is a member of the Executive Committee, Investment Risk Committee, Valuation Committee and the CLEO Committee of the General Partner. • John Novogratz, 39 Coined in 2009), is a Senior Managing Director and the Global Head of Marketing and Investor Relations
Entities connected to both Cayman Islands Tax Matters and the CLEO Committee
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