Epstein Secrets

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

owned subsidiary of Millennium International Management. 11-83 CONFIDENTIAL UBSTERRAMAR00004086 EFTA00239418 FOR EXISTING INVESTOR USE ONLY • Millennium International Management LP ("Millennium International Management"). • Blue Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium International Management.

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

ral Partner, Millennium's principal related persons that act as investment managers and management companies and manage the Fund's capital are: • Millennium International Management LP ("Millennium International Management"); • Millennium Global Estate GP LLC ("Millennium Global Estate GP"), a wholly-owned subsidiary of Millenni

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

ral Partner, Millennium's principal related persons that act as investment managers and management companies and manage the Fund's capital are: • Millennium International Management LP ("Millennium International Management"); • Millennium Global Estate GP LLC ("Millennium Global Estate GP"), a wholly-owned subsidiary of Millenni